Mandatory Patching of Serious Vulnerabilities in Government Systems

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The Cybersecurity and Infrastructure Security Agency (CISA) is responsible for building national capacity to defend American infrastructure and cybersecurity assets. In the past year they have been tasked with receiving information about American government agencies’ progress (or lack thereof) in implementing elements of Executive Order 14028: Improving the Nation’s Cybersecurity and have been involved in responses to a number of events, including Solar Winds, the Colonial Pipeline ransomware attack, and others. The Executive Order required that CISA first collect a large volume of information from government agencies and vendors alike to assess the threats towards government infrastructure and, subsequently, to provide guidance concerning cloud services, track the adoption of multi factor authentication and seek ways of facilitating its implementation, establish a framework to respond to security incidents, enhance CISA’s threat hunting abilities in government networks, and more.1

Today, CISA promulgated a binding operational directive that will require American government agencies to adopt more aggressive patch tempos for vulnerabilities. In addition to requiring agencies to develop formal policies for remediating vulnerabilities it establishes a requirement that vulnerabilities with a common vulnerabilities and exposure ID be remediated within 6 months, and all others with two weeks. Vulnerabilities to be patched/remediated are found in CISA’s “Known Exploited Vulnerabilities Catalogue.”

It’s notable that while patching is obviously preferred, the CISA directive doesn’t mandate patching but that ‘remediation’ take place.2 As such, organizations may be authorized to deploy defensive measures that will prevent the vulnerability from being exploited but not actually patch the underlying vulnerability, so as to avoid a patch having unintended consequences for either the application in question or for other applications/services that currently rely on either outdated or bespoke programming interfaces.

In the Canadian context, there aren’t equivalent levels of requirements that can be placed on Canadian federal departments. While Shared Services Canada can strongly encourage departments to patch, and the Treasury Board Secretariat has published a “Patch Management Guidance” document, and Canada’s Canadian Centre for Cyber Security has a suggested patch deployment schedule,3 final decisions are still made by individual departments by their respective deputy minister under the Financial Administration Act.

The Biden administration is moving quickly to accelerate its ability to identify and remediate vulnerabilities while simultaneously lettings its threat intelligence staff track adversaries in American networks. That last element is less of an issue in the Canadian context but the first two remain pressing and serious challenges.

While its positive to see the Americans moving quickly to improve their security positions I can only hope that the Canadian federal, and provincial, governments similarly clear long-standing logjams that delegate security decisions to parties who may be ill-suited to make optimal decisions, either out of ignorance or because patching systems is seen as secondary to fulfilling a given department’s primary service mandate.


  1. For a discussion of the Executive Order, see: “Initial Thoughts on Biden’s Executive Order on Improving the Nation’s Cybersecurity” or “Everything You Need to Know About the New Executive Order on Cybersecurity.” ↩︎
  2. For more, see CISA’s “Vulnerability Remediation Requirements“. ↩︎
  3. “CCCS’s deployment schedule only suggests timelines for deployment. In actuality, an organization should take into consideration risk tolerance and exposure to a given vulnerability and associated attack vector(s) as part of a risk‑based approach to patching, while also fully considering their individual threat profile. Patch management tools continue to improve the efficiency of the process and enable organizations to hasten the deployment schedule.” Source: “Patch Management Guidance↩︎