27.4: FedRAMP Supply Chain Requirements¶

The Federal Risk and Authorization Management Program (FedRAMP) establishes the security authorization framework for cloud services used by federal agencies. For cloud service providers (CSPs) seeking to serve the federal market, FedRAMP authorization represents both a significant business opportunity and a substantial compliance undertaking. The program's supply chain security requirements have expanded significantly following Executive Order 14028 (May 12, 2021), creating new obligations for CSPs to demonstrate visibility into and control over their software supply chains.

FedRAMP builds upon NIST SP 800-53 security controls (Rev 5, published September 2020), tailoring them to the cloud environment and adding program-specific requirements. The transition to Rev 5 baselines has introduced the new Supply Chain Risk Management (SR) control family, explicitly addressing concerns that were previously scattered across other control families or left to agency-specific interpretation. For CSPs preparing for authorization or maintaining existing authorizations, understanding these supply chain requirements has become essential to successful engagement with the federal market.

Supply Chain Control Families¶

FedRAMP supply chain requirements derive primarily from two NIST SP 800-53 control families: System and Services Acquisition (SA) and Supply Chain Risk Management (SR). Together, these families address how CSPs acquire, develop, and maintain secure systems.

SA Family: System and Services Acquisition

The SA family addresses security throughout the system development lifecycle, including controls directly relevant to software supply chain security:

SA-4 (Acquisition Process) requires CSPs to include security requirements in acquisition contracts for information systems, components, and services. Control enhancements specify:

• SA-4(1): Functional properties of security controls
• SA-4(2): Design and implementation information
• SA-4(9): Functions, ports, protocols, and services
• SA-4(10): Use of approved PIV products

For software components, SA-4 translates to documented requirements for component selection, including security assessment criteria and provenance verification expectations.

SA-9 (External System Services) addresses security when using external services, including:

• Requiring external providers to employ adequate security controls
• Defining government oversight of external services
• Establishing user roles and responsibilities for external service use

Cloud services typically depend on other cloud services, creating layered supply chain relationships. SA-9 requires documenting these dependencies and ensuring adequate security throughout the chain.

SA-10 (Developer Configuration Management) requires CSPs to:

• Track security flaws and flaw resolution
• Implement configuration management for system development
• Document and control changes to the system
• Authorize and document changes

This control directly addresses dependency management—changes to software components must follow configuration management procedures with appropriate documentation and authorization.

SA-11 (Developer Testing and Evaluation) requires security testing throughout development:

• Creating and implementing security assessment plans
• Performing unit, integration, system, and regression testing
• Producing evidence of security testing execution
• Implementing a verifiable flaw remediation process

For supply chain security, SA-11 encompasses vulnerability scanning of dependencies and security testing of component integrations.

SR Family: Supply Chain Risk Management

The SR family, new in NIST SP 800-53 Rev 5 and incorporated into FedRAMP Rev 5 baselines, provides explicit supply chain risk management controls:

SR-2 (Supply Chain Risk Management Plan) requires CSPs to develop and maintain a formal plan addressing:

• Organizational supply chain risk management strategy
• Identification and prioritization of supply chain risks
• Risk mitigation strategies and implementation approaches
• Performance metrics and assessment procedures

SR-3 (Supply Chain Controls and Processes) mandates specific controls including:

• Establishing processes for identifying and addressing supply chain weaknesses
• Limiting harm from supply chain compromises
• Employing protective measures throughout the system lifecycle
• Managing supply chain risks in accordance with organizational risk tolerance

SR-11 (Component Authenticity) at High baseline requires:

• Developing anti-counterfeit policies and procedures
• Establishing processes to detect counterfeit components
• Implementing component authentication mechanisms
• Training personnel on counterfeit detection

For software components, authenticity verification includes signature validation, checksum verification, and provenance documentation.

SBOM Requirements¶

FedRAMP's Software Bill of Materials (SBOM) requirements align with Executive Order 14028 mandates, though the specific implementation has evolved since the EO's May 2021 issuance. Currently, SBOMs are not explicitly required under FedRAMP Rev 5 baselines, but they're becoming increasingly expected and will likely be mandatory under the proposed FedRAMP 20x framework currently in pilot phase.

The FedRAMP 20x Key Security Indicators (KSI) draft specifies that CSPs "must obtain a Software Bill of Materials (SBOM) for third-party commercial software components" as part of managing supply chain risks. This represents a shift from current practice, where SBOMs support existing controls (like CM-8 for component inventory) but aren't explicitly mandated.

CSPs should:

Generate SBOMs for cloud service offerings in machine-readable formats: - SPDX (ISO/IEC 5962:2021) or CycloneDX format - Coverage of all commercial, open source, and custom components - Version information enabling vulnerability correlation - Dependency relationship documentation

Maintain SBOM currency throughout the service lifecycle: - Update SBOMs when components change - Regenerate SBOMs with each release - Timestamp SBOMs for audit traceability

Provide SBOMs to agencies upon request: - Establish delivery mechanisms (portal, API, direct transmission) - Define access controls for SBOM distribution - Document SBOM delivery in System Security Plan

FedRAMP Program Management Office (PMO) guidance emphasizes that SBOM requirements apply to the cloud service offering itself, not necessarily to every agency tenant's data or configurations. However, CSPs should clarify scope during authorization conversations to avoid misalignment with agency expectations.

Software Inventory Expectations¶

Beyond SBOMs, FedRAMP requires comprehensive software inventory management addressing:

Authorized software identification: - Maintain inventory of all software authorized for use in the cloud environment - Document authorization justification for each software component - Establish processes for adding new software to authorized inventory

Unauthorized software detection: - Implement mechanisms to detect unauthorized software - Define response procedures for unauthorized software discovery - Maintain evidence of unauthorized software detection and remediation

Continuous inventory maintenance: - Update inventory as software changes occur - Reconcile inventory with actual deployed software regularly - Document inventory discrepancies and resolution

CM-7 (Least Functionality) and CM-8 (System Component Inventory) controls specifically address software inventory. Auditors expect CSPs to demonstrate that they know what software runs in their environment and have processes to maintain that knowledge over time.

Continuous Monitoring Obligations¶

FedRAMP's continuous monitoring requirements extend to supply chain security through multiple mechanisms:

Vulnerability scanning: - Monthly vulnerability scans of operating systems and databases - Monthly web application scans for internet-facing components - Dependency vulnerability scanning aligned with organizational scanning cadence - Remediation timelines based on vulnerability severity (per FedRAMP Vulnerability Scanning Requirements): - Critical: 30 days - High: 30 days - Moderate: 90 days - Low: 180 days

ConMon reporting: - Monthly submission of vulnerability scan results - Significant change reporting when supply chain changes occur - Annual assessment covering supply chain controls - POA&M updates reflecting supply chain remediation progress

Supply chain monitoring: - Ongoing assessment of supplier security posture - Monitoring for supply chain security incidents - Tracking of component end-of-life and support status - Response to supply chain security advisories

CSPs must demonstrate that supply chain monitoring occurs continuously, not just during initial authorization. FedRAMP JAB and agencies review continuous monitoring submissions for evidence of ongoing supply chain visibility.

3PAO Assessment Considerations¶

Third Party Assessment Organizations (3PAOs) evaluate CSP compliance with FedRAMP requirements during initial authorization and annual assessments. The quality and depth of 3PAO supply chain assessments has increased significantly following Executive Order 14028. Early FedRAMP assessments often treated software supply chain as a footnote to vendor management; contemporary assessments demand detailed technical evidence.

For supply chain controls, 3PAOs typically examine:

Documentation review: - Supply Chain Risk Management Plan (SR-2) - Acquisition and procurement procedures (SA-4) - Configuration management procedures (SA-10) - Software inventory documentation (CM-8)

Technical testing: - Verification of SBOM accuracy against deployed software - Validation of vulnerability scanning coverage - Assessment of dependency management processes - Testing of software authorization workflows

Interview and observation: - Discussions with development and operations personnel - Observation of change management processes - Review of recent supply chain changes and handling

Evidence sampling: - Selection of components for provenance verification - Review of vulnerability remediation tickets - Examination of supplier assessment records

3PAO supply chain assessment depth has increased following EO 14028. CSPs should expect detailed examination of SBOM processes, vulnerability management for dependencies, and supplier risk management practices. Prepare comprehensive evidence packages addressing each supply chain control.

POA&M for Supply Chain Gaps¶

Plan of Action and Milestones (POA&M) items document security weaknesses and remediation plans. Supply chain gaps commonly appearing in POA&Ms include:

Incomplete SBOM coverage: - Components missing from SBOM - Transitive dependencies not documented - Legacy systems lacking SBOM capability

This represents one of the most common POA&M items in recent FedRAMP assessments. A CSP might have automated SBOM generation for their primary application containers but discover during assessment that their Redis deployment, Nginx instances, and monitoring agents have no SBOM coverage. Each undocumented component becomes a potential POA&M item.

Remediation approach: Implement comprehensive SBOM generation, extend tooling to legacy systems, validate coverage against deployed inventory. For systems where SBOM generation is technically challenging, document compensating controls—manual inventory with verification procedures can satisfy requirements while automated solutions are implemented.

Delayed vulnerability remediation: - Dependency vulnerabilities exceeding remediation timelines - Complex remediation requiring extended resolution time - Vendor dependencies blocking remediation

Remediation approach: Document compensating controls, escalate with vendors, evaluate alternative components for persistent issues.

Supplier assessment gaps: - Suppliers lacking formal security assessment - Missing contractual security requirements - Incomplete supplier inventory

Remediation approach: Prioritize supplier assessments by risk, update contract templates, complete supplier inventory reconciliation.

FedRAMP PMO and agencies review POA&Ms for realistic remediation timelines and appropriate risk management. Supply chain POA&M items should include: - Clear weakness description - Security impact assessment - Specific milestones with dates - Resource allocation - Compensating controls in place

FedRAMP Rev 5 Updates¶

FedRAMP's transition to NIST SP 800-53 Rev 5 baselines introduces significant supply chain security changes:

New SR family adoption: - SR controls now explicitly included in Moderate and High baselines - Formal supply chain risk management plan required (SR-2) - Supply chain controls and processes mandated (SR-3)

Enhanced SA controls: - Strengthened developer security testing requirements (SA-11) - Expanded configuration management scope (SA-10) - Additional acquisition process requirements (SA-4)

SBOM formalization: - Explicit SBOM requirements in Rev 5 implementation - Machine-readable format mandate - Integration with vulnerability management processes

Continuous monitoring expansion: - Supply chain monitoring integrated into ConMon requirements - Supply chain incidents included in incident reporting - Annual assessment coverage of supply chain controls

CSPs with existing authorizations must transition to Rev 5 baselines according to FedRAMP timelines. This transition provides an opportunity to strengthen supply chain security practices while meeting updated requirements.

Recommendations¶

We recommend CSPs pursuing or maintaining FedRAMP authorization:

1. Develop comprehensive Supply Chain Risk Management Plans addressing SR-2 requirements before assessment, including risk identification, mitigation strategies, and monitoring procedures

2. Implement automated SBOM generation integrated with build pipelines, ensuring every release produces current, accurate SBOMs in approved formats

3. Extend vulnerability scanning to cover all dependencies, not just operating systems and applications, with remediation tracking meeting FedRAMP timelines

4. Document supplier assessment procedures addressing how you evaluate and monitor component providers, including open source projects

5. Prepare 3PAO evidence packages organizing supply chain documentation, technical evidence, and process artifacts before assessment

6. Maintain POA&M currency with realistic supply chain remediation timelines and appropriate compensating controls for items requiring extended resolution

7. Track Rev 5 transition requirements ensuring supply chain controls are updated to meet new baseline expectations within required timelines

FedRAMP authorization increasingly depends on demonstrable supply chain security capability. CSPs that build robust supply chain programs will find authorization processes smoother and ongoing compliance more manageable than those treating supply chain as an afterthought.