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ARTICLE · 16 JUNE 2023

OMB Extends Timeline For Collection Of Software Attestation Forms And Clarifies Scope Of Requirement

Wiley Rein
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Agencies must collect attestations for "critical software" no later than three months after the CISA common form is approved by OMB.

United StatesTechnology
Tracye Winfrey Howard
Tracye Winfrey Howard
Teresita Regelbrugge
Teresita Regelbrugge

On June 9, 2023, the Office of Management and Budget (OMB) issued a guidance memorandum, OMB M-23-16, that extends the timeline for agencies to begin collecting attestations for critical and non-critical software from producers of software used by government agencies. As we covered in late April, the Cybersecurity and Infrastructure Security Agency (CISA) issued a draft self-attestation form (the common form) to be completed by software producers to confirm their compliance with secure software practices in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-218, Secure Software Development Framework. Notice and comment on CISA's common form is ongoing, and comments are due by June 26, 2023.

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