The White House has updated rules for federal agencies to keep logs of significant cyber activities in their networks, touting it as a measure to cut back on red tape and focus on how cybersecurity risks have evolved.
The Office of Management and Budget memorandum, released Friday, replaces a 2021 memo signed by then-President Joe Biden. It continues revisions that President Donald Trump has made to federal cybersecurity guidance under his predecessor.
The new memo, M-26-14, nods at the intentions of the earlier memo, M-21-31, saying that “Implementation of that memorandum improved foundational capabilities across agencies” to establish standards for logging and improve agencies’ record-keeping for the purposes of detecting and responding to cyberattacks.
“However, some requirements, such as the retention of vast quantities of logging data without clear utility, proved neither operationally feasible nor cost-effective for most agencies,” last week’s updated memo states. “To address these inefficiencies and the evolving cyber threat environment, this memorandum directs agencies to employ a risk-based, prioritized logging approach.”
There have been calls for the idea of updating the 2021 memo, and one observer praised the new version to CyberScoop. Another analyst, however, questioned how much harm the Trump administration might do by rescinding the earlier memo before having all of the new memo’s directives in place.
One directive is for the Cybersecurity and Infrastructure Security Agency to develop a “logging reference architecture” within 90 days that prioritizes the objectives of conducting continuous event monitoring and enabling investigations of forensic analysis after a known or suspected compromise.
Agencies would have another 90 days to submit a logging plan that adheres to those principles. The memo also establishes a new model for measuring agency progress in implementation. Multiple government watchdogs have concluded that agencies weren’t meeting the prior memo’s benchmarks.
The new memo “sharpens focus on real-time threat detection and the ability to investigate and recover after a cyber attack,” John Harmon, regional vice president of cyber solutions at Elastic, told CyberScoop. “It gives agencies the flexibility to build logging architectures that fit their specific mission.”
Harmon also praised the memo’s recognition of artificial intelligence risks to cybersecurity, and the revised maturity model.
But Nick Leiserson, senior vice president for policy at the Institute for Security and Technology think tank, said the timing of the replacement memo and the rescinding of the previous memo will give agencies a reason not to budget and prioritize logging for a period of time that adds up to six months or more.
“Moving from that to nothing is not ideal, and that’s essentially what this is doing,” Leiserson, who served in the Biden administration’s Office of the National Cyber Director, told CyberScoop. “This is saying ‘We’re rescinding 21-31 right now’ You won’t have any new guidance for at least 90 days, when CISA publishes this logging reference architecture, and it’s not clear to me why you would disaggregate that and not have the two of those things come out at the same time.”
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