DeveloperDeveloper Governance — OMB M-24-04
If you sell software to federal agencies, the December 6, 2024 deadline for secure software development attestations is here. Under OMB M-24-04, you need to certify your CI/CD controls, vulnerability response processes, and code signing practices using the Common Form. Non-critical software has until March 2025, but critical software does not get that grace period.
Fact-checked and reviewed — Kodi C.
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. catalog 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 teams 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 show 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.
Practical next steps
- 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 focus ond.
- 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.
Source material
- OMB Memorandum M-24-04 — Implementation Guidance for Federal Secure Software Development Attestations
- CISA Secure Software Development Attestation Form resources
This brief supports developer governance teams with attestation gap analysis, SBOM automation, and POA&M tracking so federal renewals stay on schedule.
Developer guidance
Development teams should adopt practices that ensure code quality and maintainability during and after this transition:
- Code review focus areas: Update code review checklists to include checks for deprecated patterns, new API usage, and migration-specific concerns. Establish review guidelines for changes that span multiple components.
- Documentation updates: Ensure README files, API documentation, and architectural decision records reflect the changes. Document rationale for setup choices to aid future maintenance.
- Version control practices: Use feature branches and semantic versioning to manage the transition. Tag releases clearly and maintain changelogs that highlight breaking changes and migration steps.
- Dependency management: Lock dependency versions during migration to ensure reproducible builds. Update package managers and lockfiles systematically to avoid version conflicts.
- Technical debt tracking: Document any temporary workarounds or deferred improvements introduced during migration. Create backlog items for post-migration cleanup and improvement.
Consistent application of development practices reduces risk and accelerates delivery of reliable software.
Continue in the Developer pillar
Return to the hub for curated research and deep-dive guides.
Latest guides
-
Secure Software Supply Chain Tooling Guide
Engineer developer platforms that deliver verifiable provenance, SBOM distribution, vendor assurance, and runtime integrity aligned with SLSA v1.0, NIST SP 800-204D, and CISA SBOM…
-
Developer Enablement & Platform Operations Guide
Plan AI-assisted development, secure SDLC controls, and runtime upgrades using our research on GitHub Copilot, GitHub Advanced Security, and major language lifecycles.
-
Continuous Compliance CI/CD Guide
Implement CI/CD pipelines that satisfy NIST SP 800-218, OMB M-24-04 secure software attestations, FedRAMP continuous monitoring, and CISA Secure-by-Design guidance while preserving…
Source material
- OMB Memorandum M-24-04 — Implementation Guidance for Federal Secure Software Development Attestations — whitehouse.gov
- CISA Secure Software Development Attestation Form resources — cisa.gov
- ISO/IEC 27034-1:2011 — Application Security — International Organization for Standardization
Comments
Community
We publish only high-quality, respectful contributions. Every submission is reviewed for clarity, sourcing, and safety before it appears here.
No approved comments yet. Add the first perspective.