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 maintain agency-wide information security programs using NIST’s **Risk Management Framework (RMF)** (NIST SP 800-37). This includes system categorization per **FIPS 199**, control selection from **NIST SP 800-53**, assessments, authorizations to operate (**ATO**), and continuous monitoring.

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 encompasses federal agencies (e.g., HHS, CMS), federal contractors, cloud service providers via **FedRAMP**, and third-party vendors processing federal data or **CUI**. State/local entities administering federal programs (e.g., Medicaid) face de facto requirements through contracts. Exclusions apply to national security systems.

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

**FISMA requires annual independent evaluations by agency Inspectors General (IGs) or external auditors, but does not mandate third-party certification.** IGs assess program maturity using CISA’s **FISMA metrics** (20 core + 17 supplemental, aligned to NIST CSF functions) across nine domains, assigning levels from Ad Hoc (1) to Optimized (5). Contractors undergo agency-directed assessments; FedRAMP provides standardized cloud authorizations.

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

**FISMA mandates annual independent IG evaluations and ongoing continuous monitoring of controls.** Agencies conduct **Security Assessment Reports (SARs)** during RMF Assess step, with **continuous diagnostics and mitigation (CDM)** for real-time monitoring of vulnerabilities, configurations, and incidents. Major incidents trigger immediate reporting to CISA/US-CERT and Congress within 30 days; full program reviews align with fiscal year-end via OMB/CISA metrics.

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

**Non-compliance with FISMA results in unfavorable IG reports, OMB remediation directives, contract losses, debarment, and reduced funding for agencies and contractors.** Agencies face operational constraints, public exposure via OMB’s annual report to Congress, and DHS binding operational directives. Contractors risk termination, suspension (e.g., DCSA actions), and False Claims Act penalties up to $100,000 per violation.

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

**FISMA does not officially map to other frameworks, but its NIST RMF and SP 800-53 controls enable practical alignment with international standards.** Agencies and contractors often leverage overlaps (e.g., SP 800-53 with ISO 27001 controls) for reciprocity, though FISMA remains U.S. federal-specific. FedRAMP supports cloud reuse without formal mappings.

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

**The first step in FISMA implementation is the RMF Prepare phase: establish governance, assign roles (CIO, CISO, Authorizing Official), and create a complete system inventory.** Develop a risk management strategy, security program charter, and **Configuration Management Database (CMDB)** as the single source of truth for federal information systems and data flows.

What is the primary objective of **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The primary objective of MLPS 2.0 is to establish a graded cybersecurity protection system ensuring security controls match the potential harm from system compromise to national security, social order, and public interests.** It classifies systems into five levels (1-5) based on impact severity, mandating technical, management, physical, and personnel controls via standards like GB/T 22239-2020, with common baselines for all levels and extensions for cloud, IoT, big data, and industrial systems.

Who is legally or professionally required to comply with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**All network operators in mainland China must comply with MLPS 2.0 under Article 21 of the 2017 Cybersecurity Law.** This includes domestic enterprises, foreign-invested firms, multinationals with local operations, cloud providers, and critical infrastructure operators in sectors like finance, energy, telecom, handling any networks or systems.

Does **MLPS 2.0 (Multi-Level Protection Scheme)** require an external audit or third-party certification?

**Yes, MLPS 2.0 requires external security reviews by licensed Chinese firms for Level 2+ systems, scoring at least 75/100 for certification.** Operators submit results to local Public Security Bureaus (PSBs) for approval; Level 3+ demands annual reviews, with PSB oversight including inspections.

How often should an assessment for **MLPS 2.0 (Multi-Level Protection Scheme)** be performed?

**Assessments under MLPS 2.0 must occur periodically: biennially for Level 2, annually for Level 3, semi-annually for Level 4, and as mandated for Level 5.** Re-evaluations are also required after major changes like architecture updates or cloud migrations.

What are the consequences of non-compliance with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**Non-compliance with MLPS 2.0 risks fines up to 100,000 yuan, operational suspensions, system shutdowns, and intensified PSB inspections.** Enforcement links certification to business license renewals; severe cases involve blacklisting or criminal liability.

Can **MLPS 2.0 (Multi-Level Protection Scheme)** be mapped to other international frameworks?

**Yes, MLPS 2.0 control domains align with frameworks like ISO 27001 and NIST CSF.** Organizational, physical, and technical controls map directly, enabling gap analyses via Statements of Applicability, though MLPS adds prescriptive grading and PSB enforcement.

What is the first step to begin implementing **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The first step is conducting a provisional self-assessment to classify systems into Levels 1-5 based on impact to national security, social order, and public interests.** Inventory assets, document rationale, then file with PSBs for Level 2+ validation.

FISMA vs MLPS 2.0 (Multi-Level Protection Scheme)

Standards Comparison

FISMA

Mandatory

2014

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

MLPS 2.0 (Multi-Level Protection Scheme)

Mandatory

N/A

China's regulation for graded cybersecurity protection of networks.

Quick Verdict

FISMA mandates risk-based security for US federal systems via NIST RMF, while MLPS 2.0 enforces graded protection for all Chinese networks with PSB oversight. Organizations adopt FISMA for federal contracts, MLPS for China operations to ensure compliance and resilience.

Cybersecurity

FISMA

Federal Information Security Modernization Act of 2014

Cost

€€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Mandates NIST RMF 7-step risk management process
Requires continuous monitoring and diagnostics program
Applies to federal agencies and contractors
Enforces annual independent IG evaluations
Demands real-time major incident reporting

Standard

MLPS 2.0 (Multi-Level Protection Scheme)

Multi-Level Protection Scheme 2.0

Cost

€€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Five-level impact-based system classification
Mandatory PSB registration for Level 2+ systems
Technical controls for cloud, IoT, big data
Governance and personnel segregation requirements
Third-party audits with law enforcement oversight

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 mandatory risk-based framework for protecting federal information and systems. It modernizes the 2002 act, emphasizing continuous monitoring, incident reporting, and NIST Risk Management Framework (RMF) with seven steps: Prepare, Categorize, Select, Implement, Assess, Authorize, Monitor.

Key Components

Integrates NIST SP 800-53 controls (20 families) tailored by FIPS 199 impact levels.
Requires agency-wide programs, System Security Plans (SSPs), POA&Ms, and annual metrics.
Oversight via OMB, DHS/CISA, IGs using maturity models aligned to NIST CSF functions.
No formal certification; compliance via independent evaluations and ATOs.

Why Organizations Use It

Federal agencies and contractors must comply to avoid penalties, debarment, funding loss. Provides risk reduction, resilience, market access (e.g., FedRAMP), operational efficiency, and trust.

Implementation Overview

Phased RMF approach: governance/inventory, categorize/select/implement controls, assess/authorize, continuous monitoring. Applies to agencies, contractors, cloud providers; scales by size/complexity with automation tools.

MLPS 2.0 (Multi-Level Protection Scheme) Details

What It Is

MLPS 2.0 (Multi-Level Protection Scheme 2.0) is China's legally enforceable cybersecurity regulation under the 2016 Cybersecurity Law (Article 21). It mandates classification of information systems into five protection levels based on potential harm to national security, social order, and public interests, requiring graded technical, organizational, and governance controls.

Key Components

Common controls across physical security, networks, data protection, operations
Level-specific baselines (GB/T 22239-2019 et al.), extended for cloud, IoT, big data, ICS
Governance structures, personnel management, incident response
Third-party audits (75/100 score minimum) and PSB certification for Levels 2+

Why Organizations Use It

Mandatory compliance avoids fines, suspensions, license risks
Enhances resilience, aligns with data laws (DSL, PIPL)
Builds regulator trust, enables market access in China
Strengthens risk management, vendor oversight

Implementation Overview

Phased: scoping, classification, gap analysis, remediation, audits, monitoring
Applies to all China network operators, critical for finance, energy sectors
Involves local PSB filing, recurring re-evaluations (annual for Level 3)

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Key Differences

Aspect	FISMA	MLPS 2.0 (Multi-Level Protection Scheme)
Scope	Federal info systems, RMF lifecycle	All networks in China, graded levels
Industry	US federal agencies, contractors	All network operators in China
Nature	Mandatory US law, NIST RMF	Mandatory Chinese regulation, PSB enforcement
Testing	Continuous monitoring, IG assessments	Third-party audits, PSB approval Level 2+
Penalties	Loss of funding, contract termination	Fines, operational suspension, inspections