TL;DR
FedRAMP Rev 5 brings major changes for Cloud Service Providers (CSPs) seeking to sell to the federal government, with a strong focus on software supply chain security. There are new controls aligned with NIST SP 800-53 Rev 5, strict hardening requirements, updated documentation, and strict transition deadlines. Understanding FedRAMP, along with Rev 5's specific implications, is essential for successfully securing and offering cloud solutions to federal agencies.
Introduction
The Federal Risk and Authorization Management Program (FedRAMP) is the gatekeeper for cloud solutions selling to the US government. The program's standards ensure a baseline level of security, reducing risk for agencies who purchase those cloud services.
With its latest revision — Rev 5 — a strong emphasis has been placed on securing the software supply chain to defend against recent attacks like SolarWinds. Container technologies have become fundamental to modern software development, and securing the way we build, package, and deploy containers is a key goal of the updated FedRAMP requirements.
Understanding FedRAMP's roadmap
FedRAMP's latest roadmap provides a valuable overview of the program's direction and priorities. This roadmap outlines four primary goals that directly support the need for stronger software supply chain security:
- Customer experience: FedRAMP aims to streamline the compliance process for CSPs, ensuring that security requirements are clear and that the path to authorization is well-defined. This focus benefits both CSPs and government agencies, enabling adoption of secure cloud solutions.
- Cybersecurity leadership: FedRAMP will set even clearer security expectations, and consistently enforce them throughout the authorization process. This promotes a proactive approach to risk management, helping to address threats within the supply chain before they can be exploited.
- Scaling a trusted marketplace: The concept of trusted partnerships is being formalized, enabling CSPs and agencies to collaborate on supply chain risk. Centralized monitoring enhances shared visibility, essential to address emerging threats.
- Smarter, technology-forward operations: FedRAMP is moving towards an API-first approach and digital authorization packages. These initiatives improve collaboration between CSPs and assessors, supporting agile responses to evolving supply chain risks.
Key changes in FedRAMP Rev 5
Let's take a closer look at the major updates introduced in FedRAMP Rev 5:
- Supply chain risk management: Rev 5 features entirely new controls specifically focused on managing risk within the software supply chain. These controls call for CSPs to assess the trustworthiness of the software they use, define appropriate policies, carefully manage third-party dependencies, and secure their software development processes with measures like code reviews and strong access controls.
- STIG hardening: The Security Technical Implementation Guides (STIGs) are now the official standard for hardening operating systems and applications that operate inside FedRAMP boundaries. Technologies that do not have a STIG can utilize the Center for Internet Security (CIS) Level 2 benchmarks. If no CIS benchmark is available providers must harden their services according to industry best practices.
- Transition timeline: CSPs must transition to Rev 5 regardless of their current authorization phase: Planning, Initiation, or Continuous Monitoring. You can find more guidance in the FedRAMP Baseline Revision 5 Transition Plan.
- Revised templates: Documentation is a cornerstone of FedRAMP. Rev 5 brings updated templates like the System Security Plan (SSP), Security Assessment Plan (SAP), and Security Assessment Report (SAR), along with additional guidance to clarify expectations and streamline the authorization process.
FedRAMP Rev 5 implications for container security
Containers offer speed and flexibility, as well as unique security complexities that Rev 5 aims to address.
Challenges of container security:
- Rapid deployment: The ease of deploying containers can introduce vulnerable components and misconfigurations.
- Ephemeral nature: Containers are often short-lived, making it difficult to track deployed components and apply patches consistently.
- Complex attack surface: Securing containers requires attention to multiple, interrelated technologies, from secure registries and images to the orchestration platform itself.
Meeting Rev 5 controls for containers:
- Image scanning: Early detection is key to preventing deployment of vulnerable software. Regularly scan images for vulnerabilities, ideally integrated into your CI/CD pipelines.
- Vulnerability management: Prioritize timely patching and mitigation of known issues. Rev 5 stresses the need for swift responses to emerging CVEs.
- Provenance tracking: Verify the source and integrity of images, ensuring use of trusted registries and employing image signing for additional assurance.
- Image hardening: Use the appropriate hardening standards to secure images before being deployed to production and verify that security remains in place.
FedRAMP: Essentials checklist
- Secure container registries: Implement strict access controls, regular vulnerability scanning, and consider image signing.
- Employ image scanning and verification: Scan images before deployment and runtime, integrating this into your development workflows.
- Regularly scan containers post-deployment: Don't stop at pre-deployment checks — continuous monitoring is vital.
- Enforce container runtime security: Apply principles like least privilege and hardening to the container runtime environment.
Streamlining your FedRAMP Rev 5 transition
The transition to FedRAMP Rev 5 compliance involves a focused effort and careful planning. Here's a breakdown of the key steps:
- Start planning early: Don't wait until the deadline! Align your container security practices with the new requirements proactively. Thoroughly review the new and updated controls and begin revising your internal policies and procedures.
- Steps to success:
- Update your security documentation (like System Security Plan (SSP) and and associated policies and procedures) to reflect Rev 5 control changes and your container-specific implementation details.
- Implement new and modified controls for container-specific requirements and update processes.
- Work closely with your Third Party Assessment Organization (3PAO) to conduct updated testing and address any findings promptly
- Manage your Plan of Action and Milestones (POA&M) actively, with swift remediation of identified risks.
- The role of automation: Look for tools that automate scanning, patching, configuration management, and policy enforcement for containers. Automation reduces manual effort, helps ensure consistency, and frees up your team to focus on more strategic tasks.
Conclusion
FedRAMP Rev 5 signifies a heightened focus on software supply chain security. CSPs working with government agencies must grasp the impact of these changes and ensure their image and container security practices meet these elevated standards. Failure to comply risks losing valuable federal business and damaging trust. Proactive compliance positions CSPs to not only gain authorizations but also to build a reputation for trustworthy, secure offerings in the federal market.
If you want to learn more about FedRAMP compliance when it comes to container security, download our Essential FedRAMP Container Security Checklist to help simplify your compliance journey.
Chainguard will soon be opening an Early Access Program for STIGs. This will further extend our FIPS images and help organizations achieve FedRAMP compliance sooner. If you're interested in participating in the STIG Early Access Program, please contact us and we'll be in touch shortly after.
