FedRAMP, FISMA, the OMB security memoranda and the NIST control catalog, CMMC for defense work, and the rules that come with criminal-justice, tax and health data.
U.S. federal (FedRAMP)Key date: January 1, 2027
FedRAMP Consolidated Rules for 2026 (CR26): timeline
Optional early adoption from July 4, 2026; mandatory adoption January 1, 2027; no new Rev5 certification applications after June 11, 2027; all grace periods end February 1, 2028.
“All stakeholders should begin incrementally adopting or transitioning to the Consolidated Rules for 2026.”
What we do: We record in the blueprint which cloud services each workload uses, with the FedRAMP status and class the FedRAMP Marketplace shows on the day of design, and check them again at every milestone.
Source: FedRAMP Consolidated Rules for 2026 (CR26) (fedramp.gov) (opens in a new tab) · Checked November 12, 2026
U.S. federal (FedRAMP)Key date: February 25, 2026
FedRAMP Certification Classes (Notice 0004 and the agency guidance on classes)
In force under the Consolidated Rules for 2026 (launched June 24, 2026; mandatory January 1, 2027), as announced in Notice 0004 of February 25, 2026: four classes from Class A (minimal assurance) to Class D; Class B includes the current LI-SaaS and Low baselines, Class C the Moderate baseline and Class D the High baseline; classes are not one-for-one replacements for impact levels.
“Agencies should not treat Certification Classes as one-for-one replacements for Low, Moderate, or High impact levels.”
What we do: Your agency categorizes the system first, and the blueprint then records, for each workload, the cloud service and the FedRAMP class it holds, ready for your agency's risk decision.
Source: FedRAMP Certification Classes (fedramp.gov) (opens in a new tab) · Checked November 12, 2026
U.S. federal (statute)Key date: December 23, 2022
FedRAMP Authorization Act: presumption of adequacy (44 U.S.C. 3613(e)(1))
In force since December 23, 2022; the Act's sunset (Pub. L. 117-263, section 5921(d)) strikes 44 U.S.C. 3607 through 3616, including this section, on December 23, 2027 unless Congress extends it.
“shall be presumed adequate for use in an agency authorization to operate cloud computing products and services.”
What we do: We build production on cloud services that hold FedRAMP authorization in the cloud your agency uses and record each one's status in the blueprint, so your agency's own authorization starts from the provider's assessed package.
Source: FedRAMP Authorization Act (law.cornell.edu) (opens in a new tab) · Checked November 10, 2026
U.S. federal (statute)Key date: December 18, 2014
FISMA: agency information security responsibilities (44 U.S.C. 3554)
In force.
“providing information security protections commensurate with the risk and magnitude of the harm”
What we do: With every system we build or run for your agency, we hand over the security evidence for our part of it: configuration as code, control implementation notes mapped to the NIST SP 800-53 controls your agency selects, test results and logging settings.
Source: FISMA (law.cornell.edu) (opens in a new tab) · Checked November 10, 2026
U.S. federal (executive agencies; national security systems and the Defense and Intelligence Community systems described in 44 U.S.C. 3553(e) excluded)Key date: May 22, 2026
OMB M-26-14: agency logging and network visibility (rescinds M-21-31)
In force since May 22, 2026; covers systems operated by third parties and the IoT/OT within them. CISA published the Logging Reference Architecture on August 20, 2026, which sets the agency deadlines: Agency Logging Plan by November 18, 2026, Level 1 (Basic) maturity by December 18, 2026, Intermediate by February 16, 2027 and Advanced by July 6, 2027.
“including any Internet of Things (IoT) devices or operational technology (OT) that is part of or constitutes such an information system”
What we do: Twin and robotics pilots log from the first sensor, and the logging design follows your agency's logging plan.
Source: OMB M-26-14 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal (executive agencies; national security systems excluded)Key date: June 24, 2026
OMB M-26-15: Execution of the Migration to Post-Quantum Cryptography
In force since June 24, 2026 (implements Executive Order 14412); agency migration plans were due October 22, 2026; prioritized systems move to post-quantum key establishment by December 31, 2030 and to post-quantum signatures by December 31, 2031, with full migration by 2035.
“Systems incapable of supporting PQC or hybrid cryptography must be identified and given priority for replacement or decommissioning.”
What we do: We put the post-quantum migration into the capital plan as a costed, scheduled line, and we price the replace-or-retire decision for each system that cannot make the move, so the run costs freed by retirement help fund the AI roadmap.
Source: OMB M-26-15 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal (executive agencies)Key date: January 23, 2026
OMB M-26-05: Adopting a Risk-based Approach to Software and Hardware Security (rescinds M-22-18 and M-23-16)
In force since January 23, 2026.
“Agencies shall continue to maintain a complete inventory of software and hardware”
What we do: The software and hardware inventory your agency keeps is where the license and application teardown starts.
Source: OMB M-26-05 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal (executive agencies)Key date: January 26, 2022
OMB M-22-09: Moving the U.S. Government Toward Zero Trust Cybersecurity Principles
Issued January 26, 2022; its FY2024 objectives have passed; no rescission found.
“For agency staff, contractors, and partners, phishing-resistant MFA is required.”
What we do: We design identity, network and data-boundary controls on zero trust principles: phishing-resistant MFA, conditional access and least privilege.
Source: OMB M-22-09 (whitehouse.gov, PDF) (opens in a new tab) · Checked November 10, 2026
U.S. federal (NIST)Key date: August 27, 2025
NIST SP 800-53 Rev. 5 (Release 5.2.0)
Current; minor release 5.2.0 of August 27, 2025.
“On August 27, 2025, NIST issued a minor release of SP 800-53 (Release 5.2.0)”
What we do: We map the controls of every system we build to the NIST SP 800-53 controls your agency selects.
Source: NIST SP 800-53 Rev. 5 (Release 5.2.0) (csrc.nist.gov) (opens in a new tab) · Checked November 10, 2026
U.S. federal (defense contracts and the defense industrial base)Key date: July 13, 2026
CMMC (DFARS 252.204-7021): Phase II suspended by the Department of War (Department of Defense)
DFARS rule effective November 10, 2025 (Phase I self-assessments in force). Phase II, scheduled for November 10, 2026, was suspended on July 13, 2026 and has not started; no new Phase II date as of November 10, 2026, and the CMMC rule texts (32 CFR part 170, DFARS 252.204-7021) are unchanged.
“The Department of War today announces the immediate suspension of the Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which were originally scheduled to come into effect on November 10, 2026. All Phase I self-assessment requirements remain firmly in place.”
What we do: For defense contractors, we design controlled unclassified information (CUI) enclaves in GCC High or Azure Government inside the contractor's tenant and assemble the evidence for its own NIST SP 800-171 Rev. 2 self-assessment.
Source: CMMC (DFARS 252.204-7021) (war.gov) (opens in a new tab) · Checked November 12, 2026
U.S. federal and state (criminal justice information)Key date: June 25, 2026
FBI CJIS Security Policy (v6.1) and Microsoft CJIS agreements
CJIS Security Policy v6.1 released June 25, 2026; Texas audits through March 31, 2027 use v5.9.5.
“All Texas CJIS audits through March 31, 2027 are conducted against FBI CJIS Security Policy version 5.9.5.”
What we do: Criminal-justice data stays inside the Microsoft government services your state's CJIS agreement covers, and we design to the policy version your auditor uses.
Source: FBI CJIS Security Policy (dps.texas.gov) (opens in a new tab) · Checked November 10, 2026
U.S. federal and state (federal tax information)Key date: November 2021
IRS Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies
Rev. 11-2021 current (IRS Safeguards page, last reviewed June 28, 2026). An early-release draft, Rev. 12-2026, takes effect 6 months after its publication date and adds a section on artificial intelligence.
“Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies … (Rev. 11-2021)”
What we do: Federal tax information stays inside the authorized government cloud boundary your safeguards review relies on, and we design the data platform to the current Publication 1075.
Source: IRS Publication 1075, Tax Information Security Guidelines for Federal, State and Local Agencies (irs.gov) (opens in a new tab) · Checked November 10, 2026
U.S. federal (HHS)Key date: January 6, 2025
HIPAA Security Rule: proposed rule to strengthen the cybersecurity of ePHI (RIN 0945-AA22)
Proposed January 6, 2025; Unified Agenda lists it under Long-Term Actions with final action 07/2027; the current Security Rule applies.
“HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information”
What we do: Where your agency is a HIPAA covered entity, such as a public hospital or a state Medicaid program, we keep protected health information in your tenant, work under a business associate agreement signed before any access, and map the design to the HIPAA Security Rule in force.
Source: HIPAA Security Rule (reginfo.gov) (opens in a new tab) · Checked November 10, 2026