What is the primary objective of **ISO 37301**?

**ISO 37301 specifies requirements for establishing, implementing, maintaining, and continually improving an effective compliance management system (CMS).** Published on 13 April 2021, it replaces the guidance-only ISO 19600 by introducing certifiable 'shall' requirements, using the Plan-Do-Check-Act (PDCA) cycle and High-Level Structure (HLS) to systematically identify compliance obligations, assess risks, embed controls, and foster a culture of integrity across all organization sizes and sectors.

Who is legally or professionally required to comply with **ISO 37301**?

**No organizations are legally required to comply with ISO 37301, as it is a voluntary certifiable standard applicable to all types, sizes, and sectors.** It is professionally adopted by entities seeking third-party validation of their CMS to demonstrate governance to regulators, investors, and partners, with proportionality scaling complexity to compliance risks, obligations, and resources.

Does **ISO 37301** require an external audit or third-party certification?

**ISO 37301 enables but does not require external audits or third-party certification.** Certification is optional via accredited bodies (e.g., ANAB-accredited), involving initial conformity assessment and surveillance audits in a typical three-year cycle, providing verifiable evidence of CMS effectiveness through documented performance evaluation and continual improvement.

How often should an assessment for **ISO 37301** be performed?

**ISO 37301 requires ongoing monitoring, measurement, internal audits at planned intervals, and periodic management reviews by top management.** Assessments follow a risk-based frequency, with certification involving surveillance audits typically annually within a three-year cycle; continual improvement mandates reactive evaluations for nonconformities and proactive reviews of CMS suitability, adequacy, and effectiveness.

What are the consequences of non-compliance with **ISO 37301**?

**Non-compliance with ISO 37301 itself carries no direct penalties, as it is voluntary, but certification withdrawal or failure to maintain CMS exposes organizations to heightened regulatory, legal, reputational, and operational risks.** Inadequate CMS may lead to unmitigated breaches of underlying obligations, fines, litigation, or lost stakeholder trust, underscoring the need for leadership-driven risk management and evidence-based performance.

Can **ISO 37301** be mapped to other international frameworks?

**Yes, ISO 37301 follows the ISO High-Level Structure (HLS), enabling seamless mapping and integration with other management system standards.** Its PDCA cycle, risk-based planning, and clauses on leadership, support, operation, evaluation, and improvement align with companion standards like ISO 37302 (effectiveness), ISO 37303 (competence), and ISO 37002 (whistleblowing), supporting Integrated Management Systems (IMS).

What is the first step to begin implementing **ISO 37301**?

**The first step is securing top management commitment and determining the organization's context, including internal/external issues and interested parties' expectations.** This initiates contextual analysis to define CMS scope, identify compliance obligations, and prioritize material risks, as outlined in Clause 4, laying the foundation for risk-based planning and leadership accountability.

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

**FISMA's primary objective is to establish 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 U.S. federal law, it requires agencies to develop, document, document, implement, implement, and continuously maintain agency-wide information security programs using NIST’s **Risk Management Framework (RMF)** (NIST SP 800-37) with its seven steps: **Prepare, Categorize, Select, Implement, Assess, Authorize, Monitor**. This ensures protections are commensurate with risk to operations, assets, individuals, other organizations, and the nation, integrating continuous monitoring and real-time incident reporting to OMB, DHS/CISA, and Congress.

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

**FISMA legally requires compliance from all U.S. federal executive branch civilian agencies and any contractors or third parties operating or hosting federal information systems or processing federal data.** This includes federal contractors (e.g., cloud providers via **FedRAMP**), systems integrators, managed service vendors, and state/local entities administering federal programs like Medicaid when handling federal data. Key roles encompass agency heads, **CIOs**, **CISOs**, Authorizing Officials (**AOs**), and Inspectors General (**IGs**). National security systems are excluded, falling under separate frameworks.

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

**FISMA does not mandate external third-party certification but requires annual independent evaluations by agency **Inspectors General (IGs)** or designees using standardized **CISA FISMA metrics**.** IGs assess program maturity across NIST Cybersecurity Framework functions (Identify, Protect, Detect, Respond, Recover), assigning levels from Ad Hoc (1) to Optimized (5), often targeting Level 4 (Managed and Measurable). Contractors face agency-driven audits; cloud providers pursue **FedRAMP** authorizations leveraging NIST SP 800-53 controls.

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

**FISMA requires annual independent program assessments by **Inspectors General (IGs)**, complemented by continuous monitoring of controls per NIST SP 800-137.** Agencies report annually to OMB via **CIO**, **IG**, and **SAOP** metrics by July 31, with real-time major incident notifications to Congress (e.g., within 30 days for significant PII breaches). System-level assessments align with **RMF** cycles, including ongoing monitoring for **ATO** maintenance, vulnerability scans, and **POA&M** tracking.

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

**Non-compliance with FISMA results in unfavorable **IG** reports, **OMB** remediation directives, operational restrictions, reduced mission effectiveness, and public scrutiny for agencies.** Contractors risk contract termination, debarment, loss of federal funding, and adverse performance ratings. Persistent failures lead to **GAO** critiques, Congressional oversight, and heightened **DHS/CISA** interventions, including binding operational directives; no direct fines are specified, but they cascade via contract clauses and False Claims Act exposure.

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

**FISMA cannot be formally mapped to other international frameworks within its standalone U.S. federal scope, as it is a mandatory statute tied exclusively to NIST standards like SP 800-53 and RMF.** While NIST controls share conceptual alignments (e.g., risk-based controls), FISMA prescribes U.S.-specific implementation via OMB Circular A-130 and CISA metrics for federal civilian systems, without reciprocity or official crosswalks to non-U.S. standards.

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

**The first step to implement FISMA is the **Prepare** phase of NIST’s **RMF**, establishing governance, roles (e.g., CIO, CISO, AO), risk tolerance, and a complete system inventory.** Develop a security program charter, **RACI** matrix, and **Configuration Management Database (CMDB)**; classify systems per **FIPS 199** (Low/Moderate/High impact). Secure executive sponsorship to align with agency-wide risk management.

ISO 37301 vs FISMA

Standards Comparison

ISO 37301

Voluntary

2021

International certifiable standard for compliance management systems

FISMA

Mandatory

2014

U.S. federal law for risk-based information security management

Quick Verdict

ISO 37301 offers voluntary global certification for compliance management systems, fostering integrity culture worldwide. FISMA mandates US federal cybersecurity via NIST RMF. Companies adopt ISO 37301 for integration and assurance; FISMA for contracts and resilience.

Compliance Management

ISO 37301

ISO 37301:2021 Compliance management systems – Requirements

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

First certifiable standard replacing guidance-only ISO 19600
High-Level Structure aligns with ISO 9001, 14001, 27001
Risk-based compliance obligations assessment and planning
Mandates leadership commitment and integrity culture
Requires confidential whistleblowing and anti-retaliation protections

Cybersecurity

FISMA

Federal Information Security Modernization Act

Cost

€€€€

Complexity

High

Implementation Time

18-24 months

Key Features

NIST RMF 7-step risk management lifecycle
Continuous monitoring and diagnostics requirements
FIPS 199 system impact categorization
Tailored NIST SP 800-53 controls
Annual IG assessments and OMB reporting

Detailed Analysis

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

ISO 37301 Details

What It Is

ISO 37301:2021 – Compliance management systems – Requirements with guidance for use is a certifiable international standard for establishing, implementing, maintaining, and improving effective compliance management systems (CMS). It applies to all organization sizes and sectors, using a risk-based approach and Plan-Do-Check-Act (PDCA) cycle via the ISO High-Level Structure (HLS).

Key Components

Core clauses: context, leadership, planning, support, operation, performance evaluation, improvement.
Emphasizes compliance obligations, risk assessment, whistleblowing, internal audits, management reviews.
Built on HLS for integration; companion standards like ISO 37302 (effectiveness), 37303 (competence).
Certifiable via accredited bodies (e.g., ANAB) with three-year audit cycles.

Why Organizations Use It

Demonstrates governance to stakeholders, reduces regulatory risks, fines, reputational damage.
Builds compliance culture, supports ESG/SDGs, enhances investor trust.
Provides certification for competitive advantage, supply chain requirements.

Implementation Overview

Phased: gap analysis, obligation register, training, audits, certification.
Scalable for SMEs to enterprises; integrates with other ISO systems.
Focuses on leadership buy-in, resources, continual improvement; 2024 amendment adds climate action.

FISMA Details

What It Is

Federal Information Security Modernization Act (FISMA) is a U.S. federal law establishing a risk-based framework for protecting federal information and systems. Enacted in 2002 and updated in 2014, it mandates agency-wide security programs focusing on confidentiality, integrity, and availability via NIST Risk Management Framework (RMF).

Key Components

**7-step RMFPrepare, Categorize, Select, Implement, Assess, Authorize, Monitor.
NIST SP 800-53 controls (over 1,000, tailored by FIPS 199 impact levels: low/moderate/high).
Continuous monitoring, System Security Plans (SSPs), Authorization to Operate (ATO), and privacy integration.
Oversight by OMB, CISA, IGs with annual metrics and maturity models.

Why Organizations Use It

Mandatory for federal agencies/contractors handling federal data.
Reduces breach risks, ensures compliance, enables federal contracts/FedRAMP.
Builds resilience, operational efficiency, executive risk decisions, stakeholder trust.

Implementation Overview

Phased RMF application: inventory, categorize, controls, assess, monitor.
Applies to agencies, contractors (incl. cloud); complex for large/federated orgs.
Involves audits, POA&Ms, no central certification but IG evaluations. (178 words)

Key Differences

Aspect	ISO 37301	FISMA
Scope	Compliance obligations, risks, culture across operations	Federal info systems security, CIA triad protection
Industry	All sectors worldwide, all organization sizes	US federal agencies, contractors, DIB primarily
Nature	Voluntary certifiable international standard	Mandatory US federal law with oversight
Testing	Accredited certification audits, 3-year cycle	Continuous monitoring, annual IG assessments, RMF
Penalties	Loss of certification, no legal penalties	Contract loss, debarment, fines, funding cuts

Scope

ISO 37301

Compliance obligations, risks, culture across operations

FISMA

Federal info systems security, CIA triad protection

Industry

ISO 37301

All sectors worldwide, all organization sizes

FISMA

US federal agencies, contractors, DIB primarily

Nature

ISO 37301

Voluntary certifiable international standard

FISMA

Mandatory US federal law with oversight

Testing

ISO 37301

Accredited certification audits, 3-year cycle

FISMA

Continuous monitoring, annual IG assessments, RMF

Penalties

ISO 37301

Loss of certification, no legal penalties

FISMA

Contract loss, debarment, fines, funding cuts

Frequently Asked Questions

Common questions about ISO 37301 and FISMA

ISO 37301 FAQ

FISMA FAQ

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ISO 37301

FISMA

Quick Verdict

ISO 37301

Key Features

FISMA

Key Features

Detailed Analysis

ISO 37301 Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

FISMA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

ISO 37301 FAQ

What is the primary objective of ISO 37301?

Who is legally or professionally required to comply with ISO 37301?

Does ISO 37301 require an external audit or third-party certification?

How often should an assessment for ISO 37301 be performed?

What are the consequences of non-compliance with ISO 37301?

Can ISO 37301 be mapped to other international frameworks?

What is the first step to begin implementing ISO 37301?

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?

You Might also be Interested in These Articles...

Asset-Backed Issuers and SEC Cybersecurity Rules: Applicability, Disclosures, and Compliance Roadmap

Why the SEC Stepped In: The Investor-Driven Push for Cybersecurity Transparency

Top 5 Reasons TISAX Tabletop Exercises Prevent €10M+ Supply Chain Breaches for ADAS Tier 1 Suppliers in 2025

Run Maturity Assessments with GRADUM

Check out these other Gradum.io Standards Comparison Pages

SOX vs ISO 17025

GDPR vs ISO 50001

ITIL vs AEO