CISA Secure by Design Principles and Code Compliance

The Cybersecurity and Infrastructure Security Agency's Secure by Design initiative establishes a foundational shift in how software manufacturers are expected to approach security — moving accountability from end users to the developers and vendors who build software products. This page covers the definition and scope of the Secure by Design framework, how its principles translate into concrete engineering and compliance practices, the organizational scenarios where it most directly applies, and the decision boundaries that distinguish compliant from non-compliant postures. Understanding this framework is essential for any organization navigating the broader landscape of code compliance in cybersecurity.

Definition and scope

CISA's Secure by Design guidance, published jointly with international partners including the UK's National Cyber Security Centre (NCSC), the Australian Cyber Security Centre (ACSC), and agencies across Canada, Germany, and the Netherlands, defines a software product as "Secure by Design" when security is treated as a core product requirement rather than an add-on feature. The foundational document — Shifting the Balance of Cybersecurity Risk: Principles and Approaches for Secure by Design Software (CISA, 2023) — identifies three overarching principles:

  1. Take ownership of customer security outcomes. Manufacturers bear responsibility for the security consequences of their design choices.
  2. Embrace radical transparency and accountability. Vendors publish CVE records, disclose vulnerabilities promptly, and maintain accurate Software Bill of Materials (SBOM) data.
  3. Lead from the top. Organizational leadership — not only engineering teams — must treat security as a business-critical objective.

The guidance targets commercial software manufacturers selling to critical infrastructure operators, federal agencies, and enterprise customers, but its principles apply to any organization producing software for external consumption. The voluntary pledge program associated with this initiative had attracted more than 250 signatories as of the program's first public reporting cycle (CISA Secure by Design Pledge).

Scope intersects directly with regulatory compliance obligations under frameworks such as NIST SP 800-218 (Secure Software Development Framework), Executive Order 14028, and the Federal Acquisition Regulation (FAR) updates requiring SBOM attestations for federal software suppliers.

How it works

Translating Secure by Design from principle to practice involves engineering controls at four discrete layers of the software development lifecycle (SDLC):

  1. Architecture decisions. Security properties — memory-safe languages, input validation schemas, privilege separation — are specified at the design phase, not patched post-deployment. CISA explicitly recommends eliminating memory-unsafe languages such as C and C++ where viable substitutes exist, citing that approximately 70% of Microsoft and Google vulnerability disclosures over multi-year periods have been attributed to memory safety errors (referenced in the CISA Secure by Design guidance citing data from Microsoft Security Response Center and Google Project Zero).

  2. Default configurations. Products ship with the most restrictive secure configurations active by default. Insecure defaults require explicit, documented opt-in — a direct inversion of the historical norm where security hardening was left to the customer.

  3. Vulnerability disclosure and transparency. Vendors maintain a published vulnerability disclosure policy (VDP) aligned with ISO/IEC 29147, respond to researcher reports within defined SLAs, and publish CVEs to the National Vulnerability Database (NVD) operated by NIST. Secure coding standards and Software Bill of Materials compliance are structural prerequisites for meeting this transparency obligation.

  4. Measurable accountability. Organizations track and report security metrics — patch deployment rates, mean time to remediate (MTTR), percentage of products with authenticated default configurations — so that progress against Secure by Design commitments is verifiable rather than declarative.

These steps connect directly to DevSecOps automation practices and shift-left security models that embed security gates early in the CI/CD pipeline.

Common scenarios

Federal software suppliers. Any vendor delivering software to a federal agency faces alignment with both CISA Secure by Design guidance and NIST SP 800-218 (SSDF). These vendors must produce SBOM attestations, complete self-attestation forms under the OMB Memorandum M-22-18, and demonstrate that their SDLC controls match the prescribed practices — or obtain a Plan of Action and Milestones (POA&M) from the purchasing agency.

Critical infrastructure operators. Energy, water, healthcare, and financial sector organizations that procure operational technology (OT) or industrial control system (ICS) software increasingly incorporate Secure by Design criteria into procurement contracts. CISA's 2024 updated guidance specifically addresses OT software manufacturers, distinguishing embedded firmware security from application-layer controls — a boundary addressed in more depth under IoT firmware code compliance.

Healthcare software developers. HIPAA-regulated entities developing or procuring patient-facing software must align CISA principles with HHS guidance on recognized security practices under the HITECH Act. The overlap between Secure by Design transparency requirements and HIPAA code compliance centers on audit logging, access control defaults, and vulnerability disclosure timelines.

SaaS and cloud vendors. Software-as-a-service providers subject to FedRAMP authorization must demonstrate Secure by Design controls as part of their System Security Plan (SSP). The FedRAMP High baseline maps to NIST SP 800-53 Rev 5 controls in families SA (System and Services Acquisition) and SR (Supply Chain Risk Management), both of which directly reflect Secure by Design accountability structures.

Decision boundaries

Distinguishing a Secure by Design-compliant posture from a non-compliant one requires examining three structural tests:

Design-time vs. deployment-time security. If security controls are introduced only after a product is built and deployed, the product does not meet Secure by Design criteria regardless of how robust those post-deployment controls are. Controls must be traceable to architecture decisions documented during the design phase.

Manufacturer vs. customer responsibility allocation. A product that requires customers to perform non-trivial hardening steps before it reaches a baseline security posture fails the Secure by Design ownership principle. The threshold test: would a non-expert enterprise operator running default settings face significant exploitable exposure? If yes, the manufacturer retains an unmet obligation.

Voluntary vs. mandated compliance. As of CISA's 2023–2024 guidance cycle, Secure by Design participation is largely voluntary for commercial vendors outside federal contracting. However, for vendors operating under Executive Order 14028 or FedRAMP, these principles carry contractual and regulatory weight. The boundary between voluntary and mandated shifts depending on the customer segment and contract vehicle.

A code compliance audit examining Secure by Design alignment must distinguish between evidence of design-phase security documentation (required) and runtime security monitoring (complementary but not sufficient on its own). The authoritative reference for compliance evidence standards remains NIST SP 800-218, Section 3, which maps Secure Software Development Framework (SSDF) tasks to corresponding evidence artifacts available at NIST SSDF.

The full framework and related code compliance resources situate Secure by Design within the broader architecture of US software security policy that has accelerated since the SolarWinds and Log4Shell incidents prompted federal action.

References

Read Next

Executive Order 14028 and Its Code Compliance Mandates Next in Regulatory Frameworks and Standards NIST SP 800-53 and Code Compliance Requirements Previous in Regulatory Frameworks and Standards