Full Report
The pledge is a voluntary framework inviting organizations to commit to foundational cyber security governance, board-level accountability, and supply chain rigor. For over a decade, Cloudflare has pioneered the core pillars of this framework: democratizing security, leadership accountability, and radical transparency.
Analysis Summary
# Regulation/Compliance: CISA Secure by Design Pledge
## Overview
The "Secure by Design" pledge is a voluntary commitment framework designed to shift the responsibility of cybersecurity from end-users to technology manufacturers. It focuses on three core pillars: democratizing security (making security features accessible to all), leadership accountability (elevating cyber risk to the board level), and radical transparency (openly sharing vulnerability and incident data).
## Key Details
- **Issuing Authority:** Cybersecurity and Infrastructure Security Agency (CISA)
- **Effective Date:** May 2024 (Initiative Launch)
- **Jurisdiction:** Global (with a primary focus on software manufacturers and service providers operating within the US ecosystem)
- **Status:** In Effect (Voluntary Framework)
## Requirements
### Mandatory Requirements (For Signatories)
*Note: While the pledge itself is voluntary to join, signatories commit to achieving progress in the following areas within one year:*
1. **Multi-Factor Authentication (MFA):** Increase the use of MFA across the manufacturer’s product base.
2. **Default Passwords:** Successive elimination of default passwords across all products.
3. **Reducing Vulnerability Classes:** Demonstrate measurable progress in reducing entire classes of vulnerabilities (e.g., memory safety issues, SQL injection).
4. **Security Patches:** Increase the installation rate of security patches by customers.
5. **Vulnerability Disclosure Policy (VDP):** Establish a public policy allowing for the good-faith reporting of vulnerabilities.
6. **CVE Reporting:** Commit to timely reporting of Common Vulnerabilities and Exposures (CVEs).
7. **Evidence of Intrusions:** Provide customers with better logs and evidence of intrusions at no additional cost.
### Recommended Practices
1. **Board-Level Oversight:** Regular reporting of cybersecurity posture and risk to the Board of Directors.
2. **Supply Chain Rigor:** Implementing Software Bill of Materials (SBOM) and auditing upstream dependencies.
3. **Open Source Contribution:** Contributing back to the security of open-source components used in proprietary products.
## Affected Organizations
- **Industries:** Software Manufacturers, Cloud Service Providers (CSPs), SaaS providers, and Hardware Manufacturers.
- **Organization Size:** Primarily targeted at enterprise-scale technology providers (e.g., Cloudflare, Microsoft, Amazon), but open to all sizes.
- **Geographic Scope:** Global; any organization providing digital products or services.
## Compliance Timeline
- **May 2024:** Official launch and initial signing period.
- **1 Year Post-Signing:** Signatories are expected to demonstrate significant progress or completion of the pledge goals.
- **Ongoing:** Periodic updates to CISA on implementation status.
## Implementation Guidance
### Assessment Phase
- Audit existing product portfolio for "Secure by Default" gaps (e.g., use of default credentials).
- Review current VDP processes and CVE reporting timelines.
- Evaluate the cost-tiering of security features (e.g., "SSO Tax").
### Implementation Phase
- Update product development lifecycles to include memory-safe languages.
- Remove default passwords from hardware/software shipped.
- Standardize MFA as a default-on configuration.
### Validation Phase
- Publicly report progress via transparency reports.
- Utilize third-party audits to verify the reduction of vulnerability classes.
## Technical Requirements
- **Memory Safety:** Transitioning codebases to languages like Rust or Go to prevent buffer overflows.
- **Logging Standards:** Providing "Security Log" parity across all licensing tiers.
- **MFA Enforcement:** Implementation of FIDO2/WebAuthn standards where applicable.
## Penalties & Enforcement
- **Fines:** None (Voluntary pledge).
- **Other Consequences:** Reputational risk; potential exclusion from future government procurement requirements if "Secure by Design" becomes a mandatory prerequisite for federal bidding.
- **Enforcement:** Public accountability through CISA's tracking of signatories.
## Related Standards
- **NIST SSDF (Secure Software Development Framework):** Aligns with the methodology for building secure software.
- **OWASP Top 10:** Directly addresses the commitment to eliminate common vulnerability classes.
- **OMB M-22-18:** Related to federal requirements for software supply chain security.
## Resources
- **Official Documentation:** hxxps[://]www[.]cisa[.]gov/securebydesign/pledge
- **Guidance Documents:** CISA "Secure by Design" Whitepaper.
- **Tools:** CISA's Stakeholder Engagement Division guidance for software manufacturers.
## Practical Recommendations
1. **Eliminate the "Security Tax":** Ensure that critical security features like SSO and advanced logging are not gated behind premium "Enterprise" tiers.
2. **Adopt Radical Transparency:** Publish detailed post-mortems for security incidents to help the broader ecosystem learn.
3. **Engage the Board:** Move cybersecurity metrics from IT dashboards to Board of Directors' risk registers to ensure financial and structural support for security initiatives.