Self-attestation is essential to compliance strategies in many different industries because it enables companies to evaluate and publicly state their internal compliance with industry norms and legal obligations. This has made them an increasingly popular tool for compliance frameworks such as the National Institute of Standards and Technology (NIST) Cybersecurity Framework and the Cybersecurity and Infrastructure Security Agency (CISA) directives.
The idea behind self-attestation is for organizations to certify that they adhere to particular security regulations and standards without needing external assessment. Attestation for frameworks supporting the technique entails obtaining the proof you require to support your compliance claims.
While self-attestation offers many advantages in terms of cost and flexibility, it also comes with certain shortcomings. You need strong procedures for gathering evidence to back up attestations made in accordance with different standards and laws. Organizations must overcome these obstacles as part of an extensive self-attestation compliance program. In this blog, we will discuss self-attestation and its benefits and drawbacks. We will also elaborate on what types of evidence are relevant for attestations.
But first, let’s define self-attestation for compliance.
What is Self-Attestation for Compliance?
In the context of cybersecurity, self-attestation is essentially an organization’s declaration that it complies with the requirements specified in a given framework or law. Software developers usually write letters to federal authorities claiming that their products adhere to the most recent cybersecurity best practices and standards.
Important compliance frameworks that offer a standard vocabulary and self-attesting mechanism for implementing cybersecurity best practices include the NIST Cybersecurity Framework. Executive Order 14028 and other government directives, thus, mandate self-attestation regarding software security. While self-attestation emphasizes evidence, federal clients can also obtain evidence through independent component analysis, configuration scans, penetration testing, and audits.
Attesting to cybersecure development helps vendors reassure government agencies that their software is reliable and compliant with the most recent cybersecurity standards.
Now, in the following couple of sections, let’s examine the challenges involved in conducting a software security self-attestation and the benefits organizations can reap if they perform one.
Challenges of Conducting a Self-Attestation for Compliance
A Software security self-attestation presents several obstacles for organizations, particularly in selling to the federal government. These include:
- It may exaggerate your security posture without third-party assessor organizations (3PAOs) doing oversight or independent validation.
- It takes time, resources, and discipline to gather thorough self-attestation from evidence across many contexts, supply chain dependencies, and systems.
- It may pose accountability risks if, following self-assessment compliance, serious software vulnerabilities surface.
- Creating a plan of action and milestones (POA&Ms) without the results of an external audit may incur additional work since you might not know where to start when it comes to improving security controls.
Organizations that want to succeed at self-attestations must establish strong procedures for ongoing software development, evidence collection, and firm-wide cybersecurity self-assessments. While self-assessments are effective, independent audits can also verify attestation rigor.
Benefits of Self-Attestation in Compliance
Here are some of the possible advantages of self-attestation in compliance:
Reduced Expenses Associated with Compliance: Software providers, particularly smaller ones, can more easily meet security standards thanks to self-attesting, eliminating the need for an external examination.
Agility in Compliance Certification: Instead of depending on prearranged external audits, self-attestation enables software vendors to validate against safe development standards on their schedules, facilitating more fluid security procedures.
Adaptability for Evidence Collection: Self-attestation enables the customization of evidence and compliance strategies depending on each vendor’s distinct business model and risk profile, even though well-known frameworks offer a common baseline.
Supply Chain Visibility for the Software: Self-attestation increases visibility throughout the software supply chain since federal agencies can request supporting documentation such as a software bill of materials (SBOM), component analysis, and security test findings.
In general, self-attestation holds software providers responsible for putting into practice secure development procedures as outlined by baseline requirements set by the government. This lowers procurement costs for federal clients and promotes safer coding practices in the commercial software sector.
So, how do self-attestation processes work in regulatory compliance? We will discuss that and what types of evidence are relevant for self-attestation below.
How Does a Self-Attestation Process Work in Regulatory Compliance?
Three main steps are involved in the self-attestation process as part of a comprehensive compliance program. These include:
Establishing a Starting Point: The organization customizes cyber frameworks, legislation criteria, and protections to fit its unique risk profile and context. This serves as the custom baseline for the attestation process.
Comparing Itself with the Starting Point: Using the modified software practices and security controls, the organization regularly evaluates itself to determine compliance and identify any gaps that need to be fixed.
Certifying Adherence: The organization drafts, reviews, approves, and archives formal attestation statements claiming compliance against the baseline using evidence gathered internally through the self-review process.
Coming to the kinds of evidence organizations can collect to validate software security self-attestation claims:
When evaluating claims of software security self-attestation, the following sources of proof are more reliable than others:
External Examinations: The most reliable reports are those from independent cybersecurity audits, which offer real third-party certification of security safeguards.
Internal Artifacts: Documentation such as secure coding policies, vulnerability logs, composition analysis reports, and developer training materials allows visibility into security procedures.
Observed Procedures: Documentation can be enhanced by direct proof, such as demonstrations or onsite assessments that visually confirm processes. Observable methods are especially beneficial for open-source software.
Restrained Self-Promotion: Verbal claims are less reliable but can be reinforced by supporting documents. Self-attestation documents that have been signed attest to accountability.
To support attestation claims, NIST advises software developers to gather multi-factor evidence from dependable sources, such as independent audits, documentation, and observed processes.
Last but not least, some examples of evidence to be collected include:
- Secure coding standards and practices.
- Software composition analysis documents.
- Vulnerability scan reports.
- Third-party component inventories.
- Developer training records.
- Penetration test results.
- Configuration monitoring records.
Whether from an internal or external audit, this proof can demonstrate that your business has applied the anticipated secure development practices throughout the software development life cycle (SDLC).
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Establishing trust is a crucial competitive differentiator when courting new SaaS businesses in today’s era of data breaches and compromised privacy. Customers and partners want assurances that their organizations are doing everything possible to prevent disclosing sensitive data and putting them at risk, and compliance certification fills that need.
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Using automated evidence collection and continuous monitoring, together with a full suite of customizable policies and controls as a compliance foundation, our compliance automation platform and services help our customers become compliance-ready for NIST’s 800-218 Secure Software Development Framework and other security standards, such as SOC 1, SOC 2, HIPAA, GDPR, PCI DSS, ISO 27001, ISO 27701, ISO 27017, ISO 27018, ISO 9001, ISO 13485, NIST CSF, NIST 800-53, NIST 800-171, FedRAMP, CCPA, CMMC, SOX ITGC, and more such as CIS AWS Foundations Benchmark, Australian ISM and Essential Eight etc. In addition, companies can use Akitra’s Risk Management product for overall risk management using quantitative methodologies such as Factorial Analysis of Information Risks (FAIR) and qualitative methods, including NIST-based for your company, Vulnerability Assessment and Pen Testing services, Trust Center, and AI-based Automated Questionnaire Response product to streamline and expedite security questionnaire response processes, delivering huge cost savings. Our compliance and security experts also provide customized guidance to navigate the end-to-end compliance process confidently. Last but not least, we have also developed a resource hub called Akitra Academy which provides easy-to-learn short video courses on security, compliance, and related topics of immense significance for today’s fast-growing companies.
The benefits of our solution include enormous savings in time, human resources, and cost savings, including discounted audit fees with our audit firm partners. Customers can achieve compliance certification fast and cost-effectively, stay continuously compliant as they grow, and become certified under additional frameworks from our single compliance automation platform.
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