FISMA
U.S. federal law mandating risk-based cybersecurity programs
ISO 27018
International code for PII protection in public clouds.
Quick Verdict
FISMA mandates risk-based security for US federal systems via NIST RMF, while ISO 27018 provides voluntary cloud PII privacy controls extending ISO 27001. Agencies comply with FISMA legally; CSPs adopt 27018 for global trust and procurement advantage.
FISMA
Federal Information Security Modernization Act of 2014
Key Features
- Mandates NIST RMF risk-based security lifecycle
- Requires continuous monitoring and ongoing authorization
- Enforces annual independent IG evaluations
- Applies to agencies and contractors handling federal data
- Overseen by OMB and CISA with binding directives
ISO 27018
ISO/IEC 27018:2025 PII protection in public clouds
Key Features
- Privacy controls for public cloud PII processors
- Subprocessor transparency and location disclosure
- Mandatory breach notification to customers
- Support for data subject rights requests
- Prohibits PII use for advertising without consent
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
FISMA Details
What It Is
Federal Information Security Modernization Act (FISMA) of 2014 is a U.S. federal law establishing a risk-based framework for protecting federal information and systems. It mandates comprehensive agency-wide information security programs using the NIST Risk Management Framework (RMF), focusing on confidentiality, integrity, and availability.
Key Components
- Seven-step RMF: Prepare, Categorize, Select, Implement, Assess, Authorize, Monitor.
- NIST SP 800-53 controls tailored by FIPS 199 impact levels.
- Continuous monitoring, incident reporting, and annual IG assessments.
- Oversight by OMB, CISA, with maturity models aligned to NIST CSF.
Why Organizations Use It
Federal agencies and contractors must comply to avoid penalties, contract loss, and debarment. It reduces risks, enables market access, builds resilience, and aligns cybersecurity with missions for strategic advantage.
Implementation Overview
Phased RMF application: inventory assets, categorize systems, deploy controls, assess, authorize, monitor continuously. Applies to agencies, contractors, cloud providers; requires SSPs, POA&Ms, audits. Scalable for large enterprises to smaller vendors via FedRAMP.
ISO 27018 Details
What It Is
ISO/IEC 27018 is a code of practice extending ISO/IEC 27001 and ISO/IEC 27002 for protecting personally identifiable information (PII) in public cloud services where providers act as PII processors. Latest edition: 2025. Scope: public cloud PII processing. Uses risk-based controls within an ISMS.
Key Components
- ~25–30 additional privacy-specific controls on consent, transparency, data minimization, subprocessors, breach notification, data subject rights.
- Aligned with ISO 27000 family, GDPR principles.
- Assessed via ISO 27001 audits; no standalone certification.
Why Organizations Use It
- Enhances trust, accelerates procurement, reduces questionnaire friction.
- Supports GDPR Article 28, HIPAA processor obligations.
- Mitigates privacy risks, aids cyber insurance.
- Differentiates CSPs, signals maturity.
Implementation Overview
- Gap analysis, integrate into ISMS/SoA, update contracts/policies.
- Training, technical safeguards like encryption/logging.
- For CSPs all sizes; annual surveillance audits.
Key Differences
| Aspect | FISMA | ISO 27018 |
|---|---|---|
| Scope | Federal info systems security, RMF lifecycle | PII protection in public cloud processors |
| Industry | US federal agencies, contractors, DIB | Cloud service providers, global CSPs |
| Nature | Mandatory US law, risk-based framework | Voluntary code of practice, ISO 27001 extension |
| Testing | Annual IG assessments, continuous monitoring | ISO 27001 audits with privacy controls review |
| Penalties | Contract loss, debarment, IG reports | No legal penalties, certification loss |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about FISMA and ISO 27018
FISMA FAQ
ISO 27018 FAQ
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