What is FISMA and who must comply?

The Federal Information Security Management Act (FISMA) was enacted in 2002 as part of the E-Government Act. Its primary purpose is to provide a framework to protect government information, operations, and assets against natural or man-made threats by requiring federal agencies to develop, document, and implement information security programs. FISMA establishes a structured approach for agencies to manage the confidentiality, integrity, and availability (CIA triad) of their information systems. 

According to a Rochester Educational paper on the topic, “In the context of FISMA, the term ‘information security’ means protecting information and information systems from unauthorized access, use, disclosure, disruption, modification, or destruction in order to ensure the confidentiality, integrity, and availability of the data.”

The law was modernized in 2014 with the Federal Information Security Modernization Act, which improved oversight roles, updated breach notification requirements, and emphasized continuous monitoring of federal information systems. The National Institute of Standards and Technology (NIST) plays a central role in providing the standards and guidelines that agencies must follow to comply with FISMA. 

These guidelines include categorizing information and systems based on risk, implementing minimum security controls, and conducting ongoing assessments to ensure compliance and risk mitigation. FISMA applies to federal agencies as well as contractors and other entities involved in handling federal information.

What it does

The Sensors (Basel) study ‘Getting Smarter about Smart Cities: Improving Data Security and Privacy through Compliance’ notes on the topic of FISMA’s application. “Federal agencies are required to ensure continuous system monitoring and each agency receives annual grade on FISMA compliance [40]; An integration to FISMA, National Institute of Standards and Technology (NIST) provides the implementation guidance for Federal Information Processing Standard (FIPS 200) by addressing seventeen control areas for risk management [37,39,40].”

FISMA establishes a formalized process for federal agencies to secure their information systems by requiring the development, documentation, and implementation of comprehensive information security programs. The law mandates agencies to assess risks, implement security controls, and continuously monitor their systems to protect against unauthorized access, use, disclosure, disruption, modification, or destruction of information. 

It requires annual reviews and reporting of security programs to the Office of Management and Budget (OMB), which oversees compliance and reports to Congress. FISMA also improves accountability by assigning responsibility to agency heads and program officials to ensure that security measures are effective and risks remain within acceptable levels. The act guides agencies to coordinate with NIST for the development and application of security standards, such as minimum security requirements and risk management frameworks.

Who must comply

According to Proceedings of the International Multiconference on Computer Science and Information Technology pages 799-806 notes on the topic of who it applies to, “FIPS 199 applies to all federal information systems except those designated as national security as defined in 44 United States Code Section 3542(b)(2).”

FISMA compliance is mandatory for all federal agencies and departments within the United States government. This includes executive branch agencies and any entities that operate or manage federal information systems. Beyond federal agencies, FISMA extends to state agencies that administer federal programs such as Medicare, student loans, and unemployment insurance, where federal information is involved. 

Private sector organizations that provide services to the federal government or receive federal grants must also adhere to FISMA requirements when handling federal data or operating information systems on behalf of the government. While private companies themselves cannot be FISMA compliant in the strictest sense because the law applies to federal agencies, they must often obtain an Authorization to Operate (ATO) that demonstrates their systems meet FISMA standards. This ensures that contractors and third-party vendors maintain adequate security controls to protect federal information.

Related: HIPAA Compliant Email: The Definitive Guide (2025 Update)

FAQs

What FISMA standards apply to software vendors?

Software vendors must follow security controls defined in NIST Special Publication 800-53, based on the impact level (low, moderate, high) determined by FIPS 199.

Do software contractors need to be FISMA certified?

FISMA does not issue certifications, but contractors must demonstrate compliance. This is typically done through a system security plan (SSP), risk assessments, and annual audits.

Are cloud-based software solutions subject to FISMA?

Yes. Cloud software used by federal agencies must meet FISMA requirements and often must be FedRAMP authorized, which builds on FISMA and NIST controls tailored for cloud security.