News & Analysis as of May 5, 2025

Cybersecurity › Software › Federal Contractors

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

SWIFT to Launch May 1: DOD Fast Tracks Software Deployment Opening New Doors for Defense Contractors

PilieroMazza PLLC on 5/1/2025

In a decisive move to stay ahead in an era of rapidly evolving digital threats, the Department of Defense (DOD) is accelerating its push for software modernization. The upcoming launch of the Software Fast Track (SWIFT)...more

DOD Mandates Use of Software Acquisition Pathway for Software Development Procurements

Wiley Rein LLP on 3/26/2025

WHAT: Department of Defense (DOD) Secretary Pete Hegseth issued a memorandum titled “Directing Modern Software Acquisition to Maximize Lethality” that is intended to reform DOD’s procurement involving software development....more

Crossing Administrations: The Focus on Federal Cybersecurity Continues

Goodwin on 3/20/2025

Federal contractors, including defense contractors, should prepare for the emergence of new requirements in the coming months that are designed to strengthen software supply chain security, impose more stringent cybersecurity...more

Analyzing President Biden's Ambitious Cybersecurity Executive Order

Davis Wright Tremaine LLP on 2/5/2025

In his final days in office, President Biden signed an ambitious executive order to improve the federal government's approach to cybersecurity. Executive Order 14114 ("Executive Order"), issued January 16, 2025, titled...more

Client Alert: White House Executive Order Seeks to Strengthen Federal Cybersecurity

Jenner & Block on 1/24/2025

On January 16, 2025, former President Biden issued the Executive Order on Strengthening and Promoting Innovation in the Nation’s Cybersecurity (the EO). The EO directs various parts of the federal government to adopt a...more

Biden Administration’s Eleventh-Hour Executive Order Imposes New Software Requirements on Companies

King & Spalding on 1/24/2025

On January 16, 2025, President Biden issued Executive Order 14144 on Strengthening and Promoting Innovation in the Nation’s Cybersecurity (the “EO”). Building on prior initiatives such as Executive Order 14028 and the...more

Biden’s Final Cybersecurity Order Proposes Significant Changes, All to Be Implemented by the Incoming Administration

Morrison & Foerster LLP - Government... on 1/20/2025

Citing the threats posed by foreign adversaries and criminal organizations, and seeking enhanced accountability for companies that provide software and cloud services to the federal government, the Biden administration has...more

They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

McCarter & English Blog: Government Contracts... on 1/17/2025

After years of anticipation, the Federal Acquisition Regulation (FAR) Council has announced the arrival of its proposed rule to enhance the safeguarding of Controlled Unclassified Information (CUI) in federal contracts (the...more

Governmental Practice Cybersecurity and Data Protection: 2024 Recap & 2025 Forecast Alert

Sheppard Mullin Richter & Hampton LLP on 1/8/2025

To kick off the New Year (and as is now tradition, since we put out a similar Recap & Forecast last year), Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2024...more

Updates on Cybersecurity Requirements for Government Contractors

Wiley Rein LLP on 11/22/2024

Part of the Biden Administration’s push to enhance U.S. cybersecurity capabilities has focused on imposing new requirements on government contractors. The 2023 National Cybersecurity Strategy suggested, for example, that...more

DOD Seeks Contractor Disclosures of Foreign Access to Software Source Code

Wiley Rein LLP on 11/21/2024

WHAT: The U.S. Department of Defense (DOD) issued a proposed rule to implement Section 1655(a) and (c) of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2019 (Pub. L. 115-232). The proposed rule would...more

CISA Unveils Final Self-Attestation Form for Software Producers Bidding on Federal Contracts

PilieroMazza PLLC on 5/1/2024

In March 2024, the Cybersecurity and Infrastructure Security Agency (CISA) released the final version of its secure software development self-attestation common form (Form), requiring federal government contractors who...more

What Does CISA’s Secure Software Development Form Mean for Contractors?

Wiley Rein LLP on 4/2/2024

WHAT: The U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) published the final version of its Secure Software Development Attestation Common Form (Common Form) and announced...more

Governmental Practice Cybersecurity and Data Protection: 2023 Recap & 2024 Forecast Alert

Sheppard Mullin Richter & Hampton LLP on 2/9/2024

To kick off the New Year, Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2023 Recap (including links to all of the resources the team has put out over the...more

“FAR” Reaching Consequences: Proposed FAR Cybersecurity Requirements Will Add New Obligations for Contractors

Paul Hastings LLP on 10/25/2023

Earlier this month the Federal Acquisition Regulation (“FAR”) Council released two draft rules which would impose new cybersecurity requirements for federal contractors. The proposed rules, Cyber Threat and Incident Reporting...more

Update: FAR Council Proposes Pair of Major Cybersecurity Rules for Government Contracts

Wiley Rein LLP on 10/12/2023

WHAT: As we previously reported here, on October 3, 2023, the Federal Acquisition Regulatory Council (FAR Council) proposed a pair of major cybersecurity rules intended to implement key parts of President Biden’s May 2021...more

Two New Cybersecurity Proposed Rules Mean Big Changes for Federal Contractors

Sheppard Mullin Richter & Hampton LLP on 10/5/2023

On October 3, 2023, the FAR Council released two long-awaited proposed rules for federal contractor cybersecurity stemming from the Biden Administration’s Cybersecurity Executive Order from May 2021 (Executive Order 14028)....more

Secure Software Regulations and Self-Attestation Required for Federal Contractors

K&L Gates LLP on 5/22/2023

Government contractors providing software across the federal government’s supply chain will be required later this year to comply with a new Secure Software Design Framework (SSDF). The SSDF requires software vendors to...more

Federal Contractors: Preparing Software Producers for Compliance with CISA’s Self-Attestation Form

PilieroMazza PLLC on 5/9/2023

As contemplated by PilieroMazza’s recent blog, the Cybersecurity and Infrastructure Security Agency (CISA) released a notice and request for comments on a new requirement for software producers to provide self-attestations...more

GSA Technology Contractors: 4 Requirements to Ensure Only Approved Software Is Used

PilieroMazza PLLC on 2/3/2023

Almost two years ago, Executive Order 14028 – Improving the Nation’s Cybersecurity (EO) was issued requiring a host of actions be taken by the Federal Acquisition Regulation (FAR) Council, the National Institute of Standards...more

OMB Renews Commitment to EO14028 by Requiring SSDF Compliance in Federal Software Acquisition

Ankura on 10/26/2022

On September 14, 2022, the Office of Management and Budget (OMB) issued much-anticipated guidance on the implementation of Secure Software Development Framework (SSDF) requirements for contractors (The “Guidance Memo”)...more

Federal Government Outlines New Security and Attestation Requirements for Software

Sheppard Mullin Richter & Hampton LLP on 9/29/2022

Per Executive Order 14028, Improving the Nation’s Cybersecurity, the Office of Management and Budget (OMB) issued a memorandum on September 14, 2022 requiring federal agencies to only use software from software producers that...more

New Security Rules for Organizations Supplying Software to the Federal Government

Jones Day on 9/27/2022

The OMB has issued memorandum M-22-18 with new security requirements (the "Rules") requiring federal agencies to ensure that all third-party software they use complies with secure software development standards and guidance...more

Federal Software Providers Need to Be Ready to Attest to NIST Compliance Within the Coming Year

Womble Bond Dickinson on 9/19/2022

Companies providing software to the federal government need to be prepared to attest that their software is NIST (National Institute of Standards and Technology)-compliant within the coming year. On September 14, 2022, the...more

DoD Re-Emphasizes Commitment to Holding Contractors Accountable on Cybersecurity

Ankura on 8/22/2022

While the DoD charts a path forward on CMMC, the USG is emphasizing the need to comply with existing cyber obligations in government contracts and taking steps to enforce compliance with those obligations. The June 16 Memo...more

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