Developer Governance Briefing — December 6, 2024

Executive briefing: The Office of Management and Budget’s Memorandum M-24-04, issued March 11, 2024, set a December 6, 2024 deadline (270 days) for U.S. civilian agencies to obtain the updated secure software development attestation from producers of critical software. Platform and release engineering leaders must prove their CI/CD controls, inventory coverage, and vulnerability response playbooks align with the Common Form before agencies can renew or award contracts.

Timeline checkpoints

Critical software deadline. Catalogue every product and service classified as “critical software” under EO 14028 and deliver completed attestations to agency buyers before December 6, 2024.
Non-critical follow-on. Track the memo’s one-year window for all other third-party software (March 11, 2025) and the requirement to refresh attestations whenever previously deferred practices are remediated.
New procurements. Apply the Common Form to any software developed after March 11, 2024 before it is installed on agency networks, ensuring acquisition teams cannot accept delivery without a current attestation.

Procurement and risk management

Contract actions. Update solicitations, task orders, and renewal packages so producers certify alignment with the Common Form statements, and explicitly reference the December 2024 cut-off in blanket purchase agreements and indefinite-delivery vehicles.
Documented risk acceptance. Use the memo’s Plan of Action and Milestones template when controls are incomplete, record the Chief Information Officer’s acceptance decision, and monitor remediation due dates inside enterprise risk registers.
Central repository. Stand up a collection mailbox or portal that routes signed forms to security, privacy, and acquisition stakeholders and can provide the artifacts to CISA on request, as required by M-24-04.

Evidence packaging

Extended documentation readiness. Pre-stage software bills of materials, build provenance files, penetration test summaries, and secure development lifecycle runbooks so agencies requesting the Common Form’s optional documentation receive complete packets.
SSDF crosswalk. Map each attestation statement to NIST Secure Software Development Framework 1.1 practices (PW.1–RV.3) and cite the CI jobs, infrastructure-as-code policies, and source protections backing each claim.
Vulnerability response cadence. Ensure incident and CVE response teams can demonstrate intake, triage, and disclosure timelines that meet the memo’s expectations for reporting material weaknesses and issuing corrected attestations.

Pipeline instrumentation

Tamper-evident builds. Maintain SLSA-aligned logs, key management, and build provenance storage so the attestation’s code signing and integrity statements have verifiable evidence.
Dependency intelligence. Integrate software composition analysis, container scanning, and infrastructure drift detection with attestation readiness dashboards to flag packages that would invalidate a signed form.
Release gating. Block promotions that lack SBOM exports, signature attestations, or approved vulnerability dispositions, mirroring the Common Form’s expectations before deployments reach federal tenants.

Enablement moves

Publish an internal attestation workbook that assigns control owners, artifact checklists, and approval states for every federal-facing product line.
Embed attestation status into program increment reviews so product, legal, and capture teams can resolve documentation gaps ahead of contracting milestones.
Schedule a quarterly joint review with security, privacy, and operations leads to reconfirm statements remain accurate and trigger updated submissions whenever release processes change.

Data stewardship

Authoritative inventories. Reconcile agency-classified critical software lists with the release engineering catalog so every binary requiring an attestation is tagged and prioritized.
Attestation mapping. Link signed Common Forms to contract numbers, SBOM hashes, and version control tags so procurement, security, and engineering teams share a single source of truth when responding to audits or renewals.
Exception logging. Record any Plan of Action and Milestones commitments or risk acceptances approved by agency partners, track due dates and compensating controls, and surface blockers to governance boards before quarterly reviews.

Post-deadline operations

Trigger refresh conditions. Define events that require resubmitting the Common Form—remediation of deferred practices, build system changes, or material vulnerabilities—and bake them into release management checklists.
Continuous monitoring. Maintain attestation coverage dashboards for CIO and acquisition leads so they can confirm compliance and respond quickly when CISA or OMB request status updates.
Supplier enablement. Publish customer contact points and secure delivery channels for signed forms, and rehearse how to furnish supporting artifacts within the Common Form’s 10-business-day expectation.

Sources

Zeph Tech supports developer governance teams with attestation gap analysis, SBOM automation, and POA&M tracking so federal renewals stay on schedule.