CISA’s SSDF Deadlines Have Passed! 14 Best Practices to Meet the Requirements and Why Every Software Company Should Care

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CISA initially set a deadline of June 11, 2023 for critical* software and September 13, 2023 for non-critical** software to comply with the Secure Software Development Framework (SSDF). Both deadlines have passed, however, there are indications that deadlines are going to be extended due to the complexity of the SSDF requirements. At the moment, SSDF requirements are mandatory for companies that want to sell their software to the government. However, I do believe that in the near future SSDF-type frameworks will be required by all businesses. In this post, I will share some information on what SSDF is, why it’s important to comply with SSDF, and best practices on how to do it the right way.

*Critical Software – software applications, systems or components essential for the operation of critical infrastructure or national security.

*Non-Critical Software – applications and systems that are not directly related to critical infrastructure or national security.

What Is SSDF? Why Did the Government Come Up with It?

Following a significant increase in the number of cyber attacks, the U.S. Federal Government issued Executive Order 14028 on Improving the Nation’s Cybersecurity in 2021. The executive order mandated that the National Institute of Standards and Technology (NIST) develop cybersecurity standards to help organizations prioritize security in their software development practices. As a result, NIST created the Secure Software Development Framework (SSDF), also known as NIST SP 800-218.

The primary goal of the SSDF is to identify guidelines and best practices to help organizations develop secure software. Executive Order 14028 states that companies that do not meet the requirements set by NIST will not be able to sell their software to the U.S. government. 

Shortly after, the Cybersecurity and Infrastructure Security Agency (CISA) set the initial deadlines mentioned above for critical and non-critical software.

What Are SSDF Implementation and Requirements for Government Suppliers?

The SSDF includes three general requirements:

1. Visibility & Remediation.

Suppliers must have a process in place to identify, assess, and remediate vulnerabilities in their software.

2. Secure Development Practices.

Software suppliers must implement a set of secure development practices throughout the software development lifecycle (SDLC), from requirements gathering to deployment and maintenance.

3. Software Supply Chain Management.

Software suppliers must have a process in place to manage the security of their software supply chain, including third-party components.

It’s worth mentioning that the SSDF requirements are not one-size-fits-all. The level of effort required to comply varies depending on the size and complexity of the software supplier’s organization, the nature of the software being developed, and the specific requirements of the government contract.

Do I Have to Comply with SSDF?

It is highly recommended for organizations to move toward SSDF compliance. At the moment, SSDF compliance  is mandatory for companies that wish to sell to U.S. government entities. 

That being said, I do believe that SSDF-type frameworks will become standard practice in software development. It is entirely possible that new regulations will come in the future, mandating SSDF adoption for all businesses.

Companies are adopting an SSDF due to the following reasons:

  1. Security benefits
  2. Gaining customers’ trust
  3. Being proactive about potential future regulations

7 Best Practices to Meet SSDF Compliance

1. Define Compliance Objectives

Establish clear compliance objectives based on the SSDF you’ve selected. This includes specific goals, timelines, and key performance indicators (KPIs) to track your progress toward compliance.

2. Perform an Assessment and Gap Analysis

First, conduct an initial assessment of your current software development processes, practices, and controls. Then identify gaps and areas where your existing processes do not meet the requirements of the selected SSDF. After this, create a comprehensive gap analysis report to understand the scope of improvements needed.

3. Assemble a Team – Security and Compliance Are a Team Sport

Assemble your team. Remember that security and compliance is a team sport. Identify the key players in your organization and assign roles and responsibilities. Work together to create a plan to achieve your goals faster. The earlier you assemble your team, the faster you’ll achieve your goal.

4. Create a Compliance Plan

Once you have objectives and a team, you can create a plan. Develop a detailed compliance plan that outlines how you will address any identified gaps. Allocate resources, responsibilities, and budgets for implementing necessary changes. Finally, define a timeline for achieving compliance milestones.

5. Perform Continuous Monitoring and Assessment

Implement continuous monitoring and assessment processes to track compliance over time. Regularly review your processes and update them accordingly. Continuous monitoring and assessment can save you a lot of time and money in the long run.

6. Documentation

Maintain thorough documentation of your security practices, procedures, and compliance efforts. Document any changes, improvements, or updates made to your development processes and controls.

7. Automation, Tool Consolidation, and ASPM

To ensure continuous SSDF compliance, consider consolidating some of the security tools that are underutilized. Instead of using many different tools, consider using one solution like an Application Security Posture Management (ASPM) platform that can perform continuous scanning of your SDLC, give you visibility and traceability from code to cloud, and remediate vulnerabilities at scale. In addition, your ASPM platform should enable you to create all the relevant documentation for SSDF automatically with the click of a button.

Cycode Can Help

Cycode can help you achieve all your compliance requirements at scale. Compliance is a complex issue. Organizations often find it difficult to understand where they have gaps because they have multiple tools with numerous controls that need to be managed. Cycode’s complete ASPM platform helps organizations aggregate all of their policies and controls, and build a cohesive compliance program. Cycode ASPM provides visibility and traceability from code to cloud. Cycode’s three core solutions – AppSec, Pipeline Security, and Application Risk – provide an open environment in which you can use our own AST scanners as well as third-party tools from outside our ecosystem. Our core solutions pull data from code to cloud across Secrets, SAST, IaC and more while automating all compliance components in one dashboard. 

7 ways Cycode can help you implement SSDF

Cycode Overview - Compliance > NIST SSDF

  1. Hardening Your SDLC Environment. Cycode’s ASPM platform, powered by our Risk Intelligence Graph (RIG), delivers full visibility into your SDLC to harden your environment from code to cloud, including CI/CD pipelines, build environments, containers, and more.
  2. Continuous Scanning & Monitoring. Cycode’s platform ensures your software is being continuously monitored for vulnerabilities from code to cloud across your CI/CD pipeline, build environments, open source components, containers, and more. Cycode’s root cause analysis identifies the fastest path to remediation. (Attestation requirements 1b, 1f.)
  3. Document Automation & Compliance in One Dashboard. Instead of manually generating documents to measure risks, Cycode automates documentation and provides all compliance artifacts in one dashboard. (Attestation requirement 1d.)
  4. Visibility & Remediation for Secrets and Encrypted Data. Cycode’s Pipeline Security solution continuously monitors sensitive data, secrets, and leaks from code to cloud. (Attestation requirement 1e.)
  5. Visibility & Remediation for Open Source & Third-Party Components. Cycode continuously monitors vulnerabilities around your open source and third-party components, providing you with visibility and auto-remediation solutions to ensure you comply with SSFD regulations. (Attestation requirement 2.)
  6. Aligning Tool Configuration with SSDF Guidelines. Cycode analyzes SDLC tool configurations and alerts when they do not align with SSDF guidelines. Cycode automatically changes tool configuration to align with SSDF guidelines. 
  7. Automatic SBOM and SLSA Document Generation. Cycode automatically generates SBOM and SLSA provenance documents during the development process to comply with the SSDF requirement “Collect, safeguard, maintain, and share provenance data for all components of each software release.” (Attestation requirement 3.)

Learn More

Read more about Cycode’s ASPM platform: Controlled Shift Left: A Strategic Blueprint for Modern Software Security with Cycode

Ready to comply with SSDF? Learn more about how Cycode delivers the only complete approach to ASPM or book a demo.