What is the primary objective of **FISMA**?

**FISMA establishes a mandatory risk-based framework for federal agencies to protect the confidentiality, integrity, and availability of federal information and information systems.** Enacted in 2002 and modernized in 2014 as part of the E-Government Act, it requires agencies to develop, document, document, implement, and assess agency-wide information security programs using NIST’s Risk Management Framework (**RMF**) in **SP 800-37**, encompassing the 7 steps: Prepare, Categorize (**FIPS 199**), Select (**SP 800-53**), Implement, Assess (**SP 800-53A**), Authorize, and Monitor.

Who is legally or professionally required to comply with **FISMA**?

**FISMA mandates compliance for all U.S. federal executive branch civilian agencies and contractors operating or hosting federal information systems.** This includes state/local entities administering federal programs (e.g., Medicaid), cloud providers via **FedRAMP**, and vendors processing federal data; national security systems are excluded. Agency heads, **CIOs**, **CISOs**, and **Authorizing Officials (AOs)** bear responsibility, with oversight by **OMB**, **DHS/CISA**, and agency **Inspectors General (IGs)**.

Does **FISMA** require an external audit or third-party certification?

**FISMA requires annual independent evaluations by agency Inspectors General (IGs) or third-party assessors, but no centralized external certification.** IGs perform assessments using **CISA FISMA metrics** aligned to NIST Cybersecurity Framework functions, assigning maturity levels (1 Ad Hoc to 5 Optimized); agencies submit via **CyberScope**, with findings reported to **OMB** for the annual FISMA Report to Congress.

How often should an assessment for **FISMA** be performed?

**FISMA mandates annual independent IG evaluations of agency-wide security programs, supplemented by continuous monitoring per NIST SP 800-137.** System-level assessments occur via **RMF** cycles, with ongoing monitoring of controls, vulnerabilities, and incidents; major incidents require real-time reporting to **CISA** and Congress (typically within 30 days for PII breaches).

What are the consequences of non-compliance with **FISMA**?

**FISMA non-compliance results in unfavorable IG reports, OMB remediation directives, operational restrictions, contract losses, and debarment for contractors.** Agencies face reduced funding, public scrutiny via OMB’s annual report to Congress, and **DHS/CISA** binding operational directives; contractors risk termination and exclusion from federal procurement.

Can **FISMA** be mapped to other international frameworks?

**FISMA does not officially map to other frameworks, as it is a U.S. federal law tied exclusively to NIST standards like SP 800-53 and RMF.** While NIST controls share conceptual alignment with voluntary frameworks, FISMA implementation relies solely on NIST SP 800-37/53/53B for federal systems, without formal mappings or reciprocity.

What is the first step to begin implementing **FISMA**?

**The first step for FISMA implementation is the RMF Prepare phase: establish governance, roles (e.g., CIO, CISO, AO), risk strategy, and a complete system inventory.** Develop a security program charter, **CMDB**, and **RACI** matrix, securing executive sponsorship to define organizational risk tolerance before Categorize (**FIPS 199**).

What is the primary objective of **AS9110C**?

**AS9110C's primary objective is to enable aviation maintenance organizations to consistently provide products and services meeting customer and applicable statutory/regulatory requirements while enhancing customer satisfaction through effective QMS application and continual improvement.** It incorporates ISO 9001:2015's high-level structure (Clauses 4–10) with aviation-specific additions like configuration management, counterfeit parts prevention, product safety, traceability, preservation, and human factors controls tailored for MRO environments such as repair stations and continuing airworthiness providers.

Who is legally or professionally required to comply with **AS9110C**?

**AS9110C applies to aviation maintenance organizations, including repair stations, MRO providers, and OEMs with autonomous maintenance operations, regardless of size.** It targets entities performing maintenance, repair, overhaul, or continuing airworthiness management on civil, private, or military aircraft/components, where certification is often mandated by customers, OEMs, or regulators for OASIS listing and supply-chain access.

Does **AS9110C** require an external audit or third-party certification?

**Yes, AS9110C requires third-party certification through accredited bodies, involving Stage 1 (documentation review) and Stage 2 (on-site implementation audit).** The QMS must be fully operational for at least three months, with a full internal audit cycle and management review completed prior to initial certification; ongoing surveillance audits occur annually, with recertification every three years.

How often should an assessment for **AS9110C** be performed?

**Internal audits for AS9110C must be performed at planned intervals based on process risk, status, and results, with full QMS coverage annually.** Management reviews occur at least annually or when significant changes arise; external surveillance audits are annual post-certification, ensuring continual suitability, adequacy, and effectiveness per Clauses 9.2 and 9.3.

What are the consequences of non-compliance with **AS9110C**?

**Non-compliance with AS9110C risks loss of certification, exclusion from OEM contracts and OASIS, regulatory sanctions like repair station certificate suspension, and safety incidents from poor configuration or counterfeit controls.** It can lead to fines, litigation, AOG events, rework costs, and reputational damage in safety-critical MRO operations.

Can **AS9110C** be mapped to other international frameworks?

**Yes, AS9110C uses ISO 9001:2015's Annex SL structure, enabling direct mapping to compatible standards via shared Clauses 4–10 and terminology like documented information and external providers.** IAQG correlation matrices support integration without overriding customer/regulatory primacy.

What is the first step to begin implementing **AS9110C**?

**The first step is to define QMS scope, perform a gap analysis against Clauses 4–10, and map internal/external issues plus interested parties per Clause 4.** Secure executive sponsorship, justify any non-applicable requirements, and produce a prioritized remediation plan integrating regulatory approvals and aviation risks.

FISMA vs AS9110C

Standards Comparison

FISMA

Mandatory

2014

U.S. federal law for risk-based cybersecurity management

AS9110C

Mandatory

2016

International standard for aviation maintenance quality management systems

Quick Verdict

FISMA mandates risk-based cybersecurity for US federal agencies and contractors via NIST RMF, while AS9110C certifies quality management for aviation MROs emphasizing maintenance safety and traceability. Agencies comply legally; MROs gain market access and operational excellence.

Cybersecurity

FISMA

Federal Information Security Modernization Act (FISMA)

Cost

€€€€

Complexity

Medium

Implementation Time

18-24 months

Key Features

Mandates NIST RMF 7-step risk management lifecycle
Requires continuous monitoring and diagnostics program
Enforces annual independent IG maturity assessments
Demands real-time major incident reporting to Congress
Extends requirements to contractors and supply chains

Quality Management

AS9110C

AS9110C Quality Management Systems for Aviation Maintenance

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Risk-based thinking in strategic and operational planning
Configuration management and traceability controls
Counterfeit and suspect parts prevention program
Human factors integration in root cause analysis
Continuing airworthiness and maintenance release requirements

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

FISMA Details

What It Is

The Federal Information Security Modernization Act (FISMA) of 2014 is a U.S. federal law mandating risk-based frameworks for protecting federal information and systems' confidentiality, integrity, and availability. It requires comprehensive agency-wide security programs via NIST Risk Management Framework (RMF).

Key Components

**7-step RMFPrepare, Categorize (FIPS 199), Select/Implement/Assess (NIST SP 800-53), Authorize, Monitor.
Continuous diagnostics (CDM), SSPs, POA&Ms, maturity models aligned to NIST CSF.
Oversight by OMB, DHS/CISA, IGs with annual metrics.

Why Organizations Use It

Mandatory for federal civilian agencies and contractors handling federal data. Enables resilience, reduces incidents, ensures FedRAMP cloud compliance, opens markets. Noncompliance risks debarment, fines, IG directives, reputational harm.

Implementation Overview

Phased RMF execution: governance/inventory, control deployment, assessments/ATOs, ongoing monitoring. Targets agencies/contractors of all sizes; requires resources, automation, audits for continuous authorization.

AS9110C Details

What It Is

AS9110C (AS9110:2016 Rev C) is an international quality management system (QMS) standard for aviation maintenance organizations (MROs), repair stations, and continuing airworthiness providers. It builds on ISO 9001:2015 with aerospace-specific requirements, using a risk-based thinking approach via Annex SL structure and PDCA cycle to ensure safe, compliant maintenance.

Key Components

10 clauses covering context, leadership, planning, support, operation, evaluation, improvement.
Core additions: configuration management, counterfeit parts prevention, human factors, traceability, product safety.
Emphasizes documented information, external provider controls, operational risk management (Clauses 6.1, 8.1.1).
Certification via IAQG-accredited bodies, listed in OASIS database.

Why Organizations Use It

Meets customer/OEM contracts, regulatory alignment (FAA/EASA Part 145).
Mitigates safety risks, improves on-time delivery, customer satisfaction.
Enhances market access, operational efficiency, supply-chain trust.

Implementation Overview

Phased: gap analysis, process design, training, audits, certification (6-12 months).
Targets MROs globally; requires internal audits, management reviews pre-certification.

Key Differences

Aspect	FISMA	AS9110C
Scope	Federal info systems security, NIST RMF	Aerospace MRO quality management, maintenance controls
Industry	US federal agencies, contractors, government	Aviation maintenance, repair organizations globally
Nature	Mandatory US federal law, risk framework	Voluntary certification standard, ISO 9001 based
Testing	Continuous monitoring, IG annual assessments	Internal audits, certification body surveillance
Penalties	Contract loss, debarment, IG reports	Loss of certification, market exclusion

Scope

FISMA

Federal info systems security, NIST RMF

AS9110C

Aerospace MRO quality management, maintenance controls

Industry

FISMA

US federal agencies, contractors, government

AS9110C

Aviation maintenance, repair organizations globally

Nature

FISMA

Mandatory US federal law, risk framework

AS9110C

Voluntary certification standard, ISO 9001 based

Testing

FISMA

Continuous monitoring, IG annual assessments

AS9110C

Internal audits, certification body surveillance

Penalties

FISMA

Contract loss, debarment, IG reports

AS9110C

Loss of certification, market exclusion

Frequently Asked Questions

Common questions about FISMA and AS9110C

FISMA FAQ

AS9110C FAQ

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FISMA

AS9110C

Quick Verdict

FISMA

Key Features

AS9110C

Key Features

Detailed Analysis

FISMA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

AS9110C Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

FISMA FAQ

What is the primary objective of FISMA?

Who is legally or professionally required to comply with FISMA?

Does FISMA require an external audit or third-party certification?

How often should an assessment for FISMA be performed?

What are the consequences of non-compliance with FISMA?

Can FISMA be mapped to other international frameworks?

What is the first step to begin implementing FISMA?

AS9110C FAQ

What is the primary objective of AS9110C?

Who is legally or professionally required to comply with AS9110C?

Does AS9110C require an external audit or third-party certification?

How often should an assessment for AS9110C be performed?

What are the consequences of non-compliance with AS9110C?

Can AS9110C be mapped to other international frameworks?

What is the first step to begin implementing AS9110C?

You Might also be Interested in These Articles...

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Top 10 Reasons CMMC Level 3 Certification Unlocks Competitive Edge for Primes Handling Critical DoD Programs

Proving CIS Controls v8.1 Works: A KPI & Evidence Framework for Board Reporting, Audits, and Continuous Assurance

Run Maturity Assessments with GRADUM

Check out these other Gradum.io Standards Comparison Pages

NIS2 vs ISO 27701

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CCPA vs ISO 41001