FISMA compliance: a checklist

The Federal Information Security Management Act (FISMA) is a U.S. federal law enacted in 2002 and updated in 2014 that establishes a comprehensive framework for protecting government information systems. It requires federal agencies to develop, document, and implement information security programs to protect their data and systems from cyber threats. FISMA applies to all federal agencies and extends to contractors and organizations that handle federal information on behalf of the government.

Under FISMA, agencies must conduct regular risk assessments, implement security controls based on the National Institute of Standards and Technology (NIST) guidelines, and continuously monitor their systems for vulnerabilities. The law mandates that agencies categorize their information systems based on the potential impact of a security breach—low, moderate, or high—and apply appropriate security measures accordingly. Agencies must also develop incident response procedures and report security incidents to designated authorities.

FISMA compliance requires annual reporting to Congress and the Office of Management and Budget (OMB) on the effectiveness of information security programs. The law establishes clear accountability by requiring agency heads to take responsibility for information security within their organizations. Non-compliance can result in significant consequences, including funding restrictions, and the law provides a framework for independent evaluation of agency security programs through inspector general assessments.

FISMA compliance steps

FISMA compliance steps:

Begin by establishing your organization's information security governance structure and obtaining leadership commitment. FISMA compliance starts with understanding your agency's role within the federal cybersecurity ecosystem, where DHS provides operational oversight and OMB maintains policy authority. Assign roles including a Chief Information Officer (CIO), Senior Agency Official for Privacy (SAOP), and system owners who will be accountable for implementing and maintaining security controls across all information systems.

Conduct comprehensive system categorization and risk assessment activities to understand your security posture. Every information system must be categorized as Low, Moderate, or High impact based on the potential adverse effects if confidentiality, integrity, or availability is compromised. Use NIST FIPS Publication 199 standards to evaluate how system compromise could affect organizational operations, assets, and individuals, then select appropriate baseline security controls from NIST SP 800-53 that correspond to your system's risk level.

Implement required security controls and document them thoroughly in System Security and Privacy Plans (SSPP). Deploy the baseline security controls identified during risk assessment, customize them based on your specific operational environment, and ensure all security measures are properly documented. Each system requires a comprehensive SSPP that details implemented controls, residual risks, and operational procedures before receiving Authorization to Operate (ATO) from designated authorities.

Establish continuous monitoring programs and conduct mandatory annual reviews to maintain ongoing compliance. Implement automated tools and processes to continuously assess security control effectiveness, track system changes, and identify emerging vulnerabilities. Agency heads and program officials must conduct annual security reviews, report major incidents to Congress and DHS as they occur, and maintain current risk assessments that demonstrate security controls remain effective against evolving threats.

FISMA compliance checklist:

• System categorization: Classify each information system as Low, Moderate, or High impact using NIST FIPS 199 criteria. Example: An agency payroll system containing employee SSNs and salary data would likely be categorized as Moderate impact due to potential financial harm and privacy violations if compromised.

• Security control selection: Select baseline security controls from NIST SP 800-53 appropriate to your system's categorization level. Example: A High impact system must implement advanced controls like multi-factor authentication, encrypted communications, and continuous monitoring tools beyond basic password requirements.

• System security plan development: Create comprehensive SSPP documentation detailing all implemented controls and risk mitigation strategies. Example: Document how your email system implements encryption controls, including specific cipher suites used, key management procedures, and certificate validation processes.

• Risk assessment execution: Conduct thorough risk assessments identifying threats, vulnerabilities, and potential impacts to organizational operations. Example: Assess risks to a citizen portal by evaluating threats like SQL injection attacks, analyzing web application vulnerabilities, and calculating potential impact on public service delivery.

• Authorization to Operate (ATO): Obtain formal authorization from designated officials confirming your system meets security requirements. Example: Submit security assessment results, SSPP documentation, and risk acceptance letters to your agency's authorizing official for ATO approval lasting up to three years.

• Continuous monitoring implementation: Deploy automated tools and processes to continuously assess security control effectiveness and system changes. Example: Implement vulnerability scanners that run weekly, configuration management tools that track unauthorized changes, and log analysis systems that identify suspicious activities.

• Incident reporting procedures: Establish processes to identify, respond to, and report major cybersecurity incidents within required timeframes. Example: Create procedures requiring security teams to notify CISA within one hour of detecting ransware infections and brief agency leadership within four hours.

• Annual review completion: Conduct comprehensive annual assessments of information security programs and submit required reports to oversight bodies. Example: Agency CIOs must evaluate security control effectiveness, update risk assessments, and submit annual FISMA metrics reports to OMB and DHS demonstrating compliance status.

Common challenges

Organizations face significant challenges in achieving compliance with FISMA's comprehensive security requirements, which demand implementation of extensive security controls tailored to their system risk categorizations. The complexity of documenting and maintaining these controls in System Security and Privacy Plans (SSPPs) while simultaneously meeting baseline security standards from NIST SP 800-53 creates substantial administrative burdens. Many organizations struggle to balance the breadth of required controls with their operational needs and available resources.

The requirement for continuous monitoring and annual security reviews presents ongoing operational challenges that strain organizational capacity and expertise. Organizations must establish robust processes to continuously monitor FISMA-accredited systems, document any changes, and respond quickly to security incidents while maintaining detailed compliance documentation. The need for regular risk assessments and system categorization updates demands specialized cybersecurity knowledge that many organizations lack internally, often requiring expensive external consultants or additional staff.

Resource allocation and coordination across multiple oversight bodies creates additional compliance complexities for organizations subject to FISMA requirements. The distributed oversight structure involving DHS for operational implementation, OMB for policy oversight, and various other agencies for specific requirements can result in conflicting guidance or duplicative reporting requirements. Organizations must navigate these multiple relationships while maintaining compliance with evolving security standards, incident reporting obligations, and data breach notification requirements that continue to expand in scope and complexity. For organizations looking to streamline this process, implementing zero trust frameworks can help simplify security architecture while meeting compliance requirements.

Simplifying FISMA compliance with an Enterprise Browser

FISMA compliance is business critical, but navigating its complex requirements can be daunting. With the Island Enterprise Browser, businesses can simplify compliance while maintaining government security and productivity — directly through the browser.

By creating secure application boundaries and embedding robust controls, Island ensures information stays within authorized systems, reducing audit scope and risk. Organizations can leverage the enterprise browser platform to provide secure access for third-party access and streamline security operations.

Frequently asked questions (FAQ)

Q: Who must comply with FISMA requirements?

A: FISMA applies to all federal agencies and extends to contractors and organizations that handle federal information on behalf of the government. Any entity that processes, stores, or transmits federal information must meet FISMA compliance requirements.

Q: What are the three FISMA system categorization levels and how are they determined?

A: Systems are categorized as Low, Moderate, or High impact based on the potential adverse effects if confidentiality, integrity, or availability is compromised. The categorization follows NIST FIPS Publication 199 standards and considers how system compromise could affect organizational operations, assets, and individuals.

Q: How often must organizations conduct FISMA compliance activities?

A: Organizations must conduct annual security reviews and submit annual reports to Congress and OMB. Additionally, continuous monitoring must be implemented to assess security control effectiveness on an ongoing basis, and Authorization to Operate (ATO) approvals typically last up to three years before renewal.

Q: What happens if an organization fails to achieve FISMA compliance?

A: Non-compliance can result in significant consequences, including funding restrictions. The law provides a framework for independent evaluation through inspector general assessments, and agency heads are held directly accountable for information security within their organizations.

Q: What key documentation is required for FISMA compliance?

A: The primary requirement is developing comprehensive System Security and Privacy Plans (SSPP) for each information system. These plans must detail all implemented security controls, residual risks, operational procedures, and risk mitigation strategies before systems can receive Authorization to Operate from designated authorities. For additional guidance and resources, organizations can access relevant whitepapers or contact us for expert assistance.