FedRAMP RFC-0012
What Application Security Teams Must Do to Comply with the New Continuous Vulnerability Management Standard
FedRAMP’s RFC-0012 significantly raises the bar for vulnerability management in cloud environments. Application security teams must now adopt continuous, automated vulnerability detection, prioritize remediation by real-world exploitability, and maintain rigorous, transparent reporting practices.
Key Takeaways:
- Continuous vulnerability scanning (every ≤3 days).
- Contextualized vulnerability prioritization beyond CVSS.
- Rapid remediation with defined timelines (≤3 days for high-risk, internet-facing assets).
- Enhanced transparency, reporting, and audit readiness.
Introduction
The Federal Risk and Authorization Management Program (FedRAMP) recently released RFC-0012, marking a notable shift towards more stringent standards for continuous vulnerability management. Cloud providers and security teams must adjust quickly to stay compliant and secure (FedRAMP, 2024).
How Kodem Can Help
Kodem provides cloud providers and security teams with the tools needed to meet the rigorous standards introduced by FedRAMP’s RFC-0012. By integrating continuous scanning into existing DevSecOps pipelines, Kodem identifies vulnerabilities across the full application lifecycle—code, runtime, and configurations. Kodem’s contextual prioritization engine accurately assesses exploitability and reachability, enabling teams to focus efforts on high-risk issues. Additionally, automated remediation workflows and transparent reporting capabilities help organizations achieve compliance seamlessly and efficiently.
Implications for Application Security Teams
Increased Scanning Cadence and Scope
Continuous scanning is now mandatory. Security teams must shift from periodic manual checks to automated, ongoing vulnerability detection. External-facing applications require scans every three days, significantly shortening traditional cycles (FedRAMP, 2024).
Contextualized Risk Prioritization
RFC-0012 goes beyond CVSS scores, demanding a deeper understanding of real-world exploitability. Teams must integrate data on asset exposure, traffic patterns, and active threats to effectively prioritize risks, highlighting a need for integrated threat intelligence solutions (FedRAMP, 2024).
Accelerated Remediation Timelines
Clearly defined service level agreements (SLAs) now apply, such as a three-day window for remediating exploitable internet-facing vulnerabilities. Achieving compliance requires automated pipelines and rapid-response workflows tightly integrated with development and operational teams (FedRAMP, 2024).
Enhanced Transparency and Reporting
Providers must maintain detailed, structured vulnerability reports accessible for audits and mandatory disclosures to FedRAMP, CISA, and customer agencies. This new standard necessitates investment in reporting infrastructure and tooling for generating machine-readable outputs (FedRAMP, 2024).
Recommended Actions
To comply effectively:
- Embed automated vulnerability scanning into CI/CD pipelines.
- Implement auto-generated remediation tickets linked directly to scanning outputs.
- Establish dashboards and automated reporting aligned with FedRAMP requirements.
- Define clear roles and escalation paths within the application security governance structure.
Conclusion
RFC-0012 represents a significant evolution in FedRAMP standards, emphasizing automation, contextual risk assessment, and stringent governance. Cloud service providers must rapidly enhance their security infrastructure and operational processes to meet these new, more rigorous expectations.
References
FedRAMP. (2024). RFC-0012 Continuous Vulnerability Management Standard. Retrieved from https://www.fedramp.gov/rfcs/0012/
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