Full Report
The U.S. Department of Defense (DoD) released on Monday details of an initiative, ‘Accelerating Secure Software,’ and kicked... The post US DoD gets set to develop SWFT framework, issues RFIs to advance secure software development and authorization appeared first on Industrial Cyber.
Analysis Summary
# Regulation/Compliance: Accelerating Secure Software Initiative (Software Fast Track - SWFT)
## Overview
The DoD’s ‘Accelerating Secure Software’ initiative, culminating in the Software Fast Track (SWFT) framework, aims to fundamentally reform how the Department of Defense obtains, develops, authorizes, and fields secure software. The goal is to replace outdated, slow software procurement and authorization processes with mechanisms that define clear cybersecurity and Supply Chain Risk Management (SCRM) requirements, implement rigorous verification, and expedite software adoption via federal risk determinations.
## Key Details
- Issuing Authority: U.S. Department of Defense (DoD), directed by the DoD CIO (Katie Arrington).
- Effective Date: The Framework and Implementation Plan are slated for development within 90 days of the announcement.
- Jurisdiction: U.S. Department of Defense systems, contractors, and software providers interacting with the DoD.
- Status: Initiative Launched (Framework in development via 90-day sprint).
## Requirements
### Mandatory Requirements (Inferred from objectives & RFI topics for future mandatory framework)
1. **Define Cybersecurity and SCRM Requirements:** The final SWFT framework will mandate clear, specific controls for cybersecurity and Supply Chain Risk Management.
2. **Rigorous Software Security Verification:** Implementation of verification processes to ensure software quality and security before deployment.
3. **Secure Information Sharing:** Establishment of mechanisms for secure and consistent information exchange related to software security posture.
4. **SBOM Provision (Commercial Software):** Commercial software products may be required to provide a Software Bill of Materials (SBOM) including component-level (artifact-level) details.
5. **Risk Assessment Artifact Sharing:** Organizations must be prepared to share software risk assessment artifacts with the DoD to support consistent DoD-led risk determinations.
6. **Implementation of Secure Development Practices:** Potential assessment of how organizations implement practices outlined in **NIST SP 800-218** (Secure Software Development Framework - SSDF).
### Recommended Practices (Inferred from RFI scope)
1. **Use of Automated Tools:** Utilizing automated tools to generate software risk assessment artifacts.
2. **Leveraging Industry Standards:** Identifying and leveraging specific industry standards for secure software development.
3. **External Assessment Function:** Maintaining an audit function (internal or external) that specifically assesses software security.
4. **Automation/AI Integration:** Exploring methods for automation or AI to assist in streamlining DoD-led SWFT risk assessments within the RMF.
## Affected Organizations
- **Industries:** Defense Industrial Base (DIB) contractors, software vendors, solution providers, and any entity developing or providing software used by the DoD.
- **Organization Size:** Applicable regardless of size, especially vendors providing commercial off-the-shelf (COTS) or custom software.
- **Geographic Scope:** Primarily dictates U.S. federal contracting requirements for software deployed or utilized by the DoD globally.
## Compliance Timeline
- **90 Days Post-Announcement (Approx. May/June 2024):** Submission of the complete Software Fast Track (SWFT) Framework and Implementation Plan.
- **May 20, Noon EST:** Deadline for all three Requests for Information (RFI) responses.
- **Post-Framework Release:** Organizations must adhere to timelines established within the final SWFT Implementation Plan for adopting new verification and authorization processes.
## Implementation Guidance
### Assessment Phase
- **Tool Readiness:** Identify existing tools for generating SBOMs and software risk artifacts, and assess the feasibility of sharing these artifacts with the DoD.
- **SSDF Alignment Check:** Review current secure software development practices against the guidance provided in NIST SP 800-218; document any obstacles to implementation or attestation.
- **External Assessment Review:** Determine if an existing software security audit function is in place (internal/external) and if it aligns with any existing compliance regimes.
### Implementation Phase
- **Information Sharing Strategy:** Develop methods to support secure, automated information sharing to satisfy rigorous verification processes.
- **SBOM Gaps:** If commercial software is supplied without an SBOM, develop a plan to generate one or document the obstacles preventing it.
- **Automation Planning:** Evaluate how automation and AI can be integrated into existing development and risk assessment workflows to meet future SWFT requirements.
### Validation Phase
- **Artifact Suitability:** Confirm that generated risk assessment artifacts are suitable for consistent and secure DoD-led risk assessments.
- **Process Documentation:** Document adherence to new security verification processes introduced by the SWFT framework.
## Technical Requirements
- **SBOMs:** Provision of component-level SBOMs for commercial software products.
- **Artifact Generation:** Capability to produce verifiable artifacts used for software risk assessment, potentially via automated tools.
- **Secure Information Sharing:** Technical mechanisms supporting secure and automated data exchange regarding software security posture.
## Penalties & Enforcement
- **Fines:** Not explicitly detailed in the announcement, but penalties will likely align with existing FAR/DFARS clauses for non-compliance in software security and SCRM, potentially leading to contract termination or exclusion from future DoD contracts.
- **Other Consequences:** Delayed or denied software authorization (which directly impacts deployment speed), loss of visibility/trust, and scrutiny under federal risk determinations.
- **Enforcement:** Enforcement will be driven by the federal government-led risk determinations within the new SWFT process, likely involving the DoD CIO office and relevant acquisition/security organizations.
## Related Standards
- **NIST SP 800-218:** Secure Software Development Framework (SSDF) – Referenced for guidance on secure development practices.
- **DoD Risk Management Framework (RMF):** SWFT risk assessments are expected to be integrated within or leverage structures defined by the existing DoD RMF.
- **CMMC 2.0:** While distinct, the announcement follows an audit report noting issues in CMMC Level 2 assessment authorization, suggesting SWFT will enforce high assurance requirements similar to those underlying CMMC compliance.
## Resources
- **Official Documentation:** DoD News Release: Accelerating Secure Software Initiative (Search for the provided links in context for the original release and associated memo).
- **Guidance Documents:** Memo signed by Katie Arrington to senior Pentagon leadership detailing the initiative (available via DoD CIO website).
- **Tools:** Industry input sought via RFI #1 regarding commercial tools that support secure software development, SBOM generation, and risk artifact creation.
## Practical Recommendations
1. **Engage Immediately:** Respond to the three RFIs (SWFT Tools, External Assessment Methodologies, Automation/AI) by the May 20 deadline to help shape the final framework requirements.
2. **Prioritize SSDF:** Begin mapping current secure development pipelines immediately against NIST SP 800-218 to close assurance gaps proactively.
3. **SBOM Capability:** Ensure processes are in place to generate accurate, artifact-level SBOMs for all software offered to the DoD, or clearly document the technical hurdles preventing this if necessary.
4. **Risk Artifact Planning:** Prepare documentation and automated methods to furnish risk assessment artifacts to DoD assessors upon request.