If you’ve been working in federal cybersecurity for any length of time, you already know the feeling. You spend months meticulously documenting controls, filling out spreadsheets, copying and pasting evidence between ten different tools, and by the time you finally get your Authorization to Operate, half of your documentation is already out of date. Your system has changed. Your vulnerabilities have shifted. And yet, your compliance artifacts are frozen in time, waiting for the next annual assessment to catch up with reality.
The Department of War knows this too. That’s why in September 2025, they released the Cybersecurity Risk Management Construct—a fundamental reimagining of how we approach cyber risk management across DoW systems. If you haven’t seen it yet, CSRMC isn’t just an incremental update to the Risk Management Framework. It’s a wholesale shift from static, point-in-time assessments to continuous authorization, real-time monitoring, and risk management that actually keeps pace with the systems we’re trying to protect.
Why the Change Was Inevitable
Let’s be honest: traditional RMF implementation has become a paperwork exercise that often feels disconnected from actual security. We’ve all seen it. Controls get documented because they have to be documented, not because the documentation provides meaningful risk visibility. POA&Ms kick cans down the road rather than driving real remediation. Authorization packages are obsolete before the ink dries—or more accurately, before the digital signature is applied.
The CSRMC document itself puts it plainly: the goal is to produce “a culture, mindset and process that reimagines cyber risk management to be faster in keeping with the rate of change; more effectively assesses and conveys risk; and is less burdensome to cyber and acquisition professionals while ultimately providing operational combatant commanders with an accurate understanding of cyber risk to mission.”
That last part is critical. Operational commanders need to understand cyber risk in real time, not six months after an assessment team packed up and left. The objective isn’t just faster ATOs—it’s continuous authorization that reflects the actual state of your system as it evolves.
CSRMC introduces a five-phase lifecycle approach: Design, Build, Test, Onboard, and Operations. Unlike the old RMF steps, these phases are designed to parallel system development and deployment, embedding cybersecurity decisions directly into engineering and operations rather than treating them as a separate compliance track. Automation, continuous monitoring, and what they’re calling “critical controls” focus are no longer nice-to-haves. They’re foundational tenets.
The Transition Challenge That Will Define the Next Two Years
Here’s where it gets complicated. CSRMC represents the future, but we’re all living in the present. You can’t just flip a switch and move from RMF to CSRMC overnight. Government agencies are going to transition at different speeds. Some programs will adopt CSRMC quickly while others continue with traditional RMF approaches for years. If you’re supporting multiple agencies, you’ll need to work in both paradigms simultaneously.
And if you’re a commercial company or federal contractor who primarily delivers IT products or services—not compliance expertise—you’re about to face a new challenge. CSRMC requirements are starting to appear in RFPs and procurement documents as standard expectations for any IT contract, not just dedicated cybersecurity programs. You’re being asked to demonstrate continuous authorization capabilities while also delivering your actual product or service. For many organizations, this means navigating RMF and now CSRMC without the luxury of a dedicated compliance team or deep federal cybersecurity expertise.
The tooling problem compounds this challenge. Most compliance platforms were built for the old world—static documentation, point-in-time assessments, and manual evidence collection. As CSRMC implementation accelerates, it’s worth being thoughtful about how different solutions approach continuous authorization. The architecture underneath matters more than the marketing on top.
What Continuous Authorization Actually Requires
Here’s what many people miss about continuous authorization: it’s not just about speed. It’s about maintaining accurate state.
In the traditional RMF world, you could build a system, freeze it for assessment, get your ATO, and then deal with the slow drift between your actual system and your compliance documentation. Everyone knew the documentation lagged reality, but as long as you weren’t too far out of compliance, the annual reassessment would catch up eventually.
Continuous authorization doesn’t allow that drift. If your authorization is continuous, your compliance artifacts need to continuously reflect your actual system state. That means when you patch a server, your POA&M status updates. When you add a new asset, your system diagrams regenerate. When your architecture changes, your documentation reflects it automatically. This isn’t about generating documents faster—it’s about fundamentally different data architecture.
The really hard part is integration. Continuous monitoring requires pulling data from vulnerability scanners, asset management systems, configuration management databases, security tools, and operational systems. That data needs to flow automatically, not through manual imports or scheduled batch jobs. When a vulnerability scanner detects a new finding, that information needs to propagate through your POA&M management, control assessment, and reporting systems without someone copy-pasting between tools.
Most organizations attempting this discover they don’t actually have continuous monitoring—they have SharePoint sites and manual processes that are supposed to function as ISCM but really don’t. The integration layer is missing. Data lives in silos. Updates require human intervention.
This is why the architecture question matters. Some platforms are purpose-built with data flows and integrations as foundational design elements. Others are adapting point-in-time assessment tools with new dashboards and hoping that counts as continuous monitoring. Both approaches might claim CSRMC readiness, but they’re solving fundamentally different problems.
Critical Controls and Environment Awareness
One of CSRMC’s most important philosophical shifts is the focus on critical controls rather than comprehensive checkbox compliance. Not every control requires the same level of attention, and more importantly, not every control can be automated the same way because environments vary.
This is where Organization-Defined Parameters (ODPs) become critical. A control like AC-2 (Account Management) might specify that accounts must be reviewed every [Assignment: organization-defined frequency]. One system might define that as monthly. Another might define it as quarterly. A third system in a high-security environment might define it as weekly. They’re all compliant with the same control, but the implementation and evidence collection look completely different.
Effective continuous authorization platforms need to handle this variability. You can’t just template all controls the same way. You need environment-aware automation that understands how your specific ODPs affect evidence collection, assessment procedures, and continuous monitoring requirements.
Teams that get this right typically use tiered automation approaches. High-risk controls and critical security functions get deep automation with real-time evidence collection. Medium-risk controls might use periodic automated checks. Lower-risk controls that are well-established might rely on lighter touch monitoring with alerts only for significant changes.
The key is that the platform needs to support this flexibility rather than forcing every control through the same automation pipeline.
DevSecOps Integration: Security From Design, Not Authorization
CSRMC’s Design phase is explicit about this: cybersecurity decisions need to happen at system conception, not during authorization. This aligns with what successful DevSecOps teams have been advocating for years—security can’t be bolted on at the end.
In practice, this means your compliance platform needs to support early-stage activities that traditional RMF tools ignored. Before you write a line of code, you should be evaluating what controls apply to your system based on its intended function and environment. You should be performing software risk assessments that inform architecture decisions. You should be tracking security requirements alongside functional requirements in your project planning.
The teams doing this well treat their compliance platform as a planning tool, not just an assessment tool. They’re using it to generate task lists for developers, identify security patterns to implement, and validate architectural decisions against compliance requirements before committing to designs that will be expensive to change later.
This is particularly important for commercial companies and contractors who are encountering RMF requirements for the first time through procurement contracts. If you wait until you’ve built your system to think about compliance, you’re going to discover requirements that force expensive redesign. If you can evaluate RMF implications during initial architecture planning, you can make informed tradeoffs between different design approaches based on their compliance implications.
Reciprocity: The Underappreciated CSRMC Opportunity
CSRMC’s emphasis on reciprocity—accepting assessments across programs and reusing authorizations—deserves more attention than it typically gets. This isn’t just about reducing duplicative work, though that’s valuable. It’s about building institutional knowledge that can be leveraged across an organization.
Think about software risk assessments. In traditional workflows, every program office might assess the same commercial product independently. One office evaluates Kubernetes and determines it’s acceptable for their use case. Another office evaluates the exact same version of Kubernetes six months later and redoes all the same analysis. A third office is evaluating it right now. Nobody’s work benefits anyone else.
Effective reciprocity changes this dynamic. When one team completes a thorough risk assessment and approves a product, that assessment becomes immediately available to every other team in the organization. They can review the existing analysis, confirm it applies to their use case, and attach the approval to their system—done. No duplicate effort. No waiting for another round of analysis.
The barrier to reciprocity usually isn’t policy—most organizations already have reciprocity policies. The barrier is mechanics. How do you actually share the assessment? Where do you store it so other teams can find it? How do you track what version was assessed? How do you handle updates when new vulnerabilities are discovered?
Platforms that solve reciprocity well treat it as a first-class feature, not an afterthought. Organizational-level approval workflows, searchable approval registries, version tracking, and one-click attachment to systems aren’t exotic features—they’re table stakes for making reciprocity actually work instead of being a theoretical policy that nobody uses.
Real-Time Dashboards Versus Real-Time Decisions
CSRMC’s Operations phase emphasizes real-time dashboards and automated alerting, and this is where many platform evaluations go wrong. It’s easy to demonstrate a dashboard. It’s much harder to demonstrate that the dashboard is showing accurate, current data and that alerts trigger meaningful action.
The questions worth asking: How fresh is this data? Is the dashboard pulling from yesterday’s scan results or is it connected to continuous feeds? When a critical vulnerability appears, does someone get notified automatically or do they have to remember to check the dashboard? When an automated control drifts out of compliance—maybe because underlying evidence was deleted or a data connection failed—does anyone know?
More importantly: what happens when an alert fires? Does it create a task? A POA&M? Does it escalate to the right people based on severity? Or does it just light up a dashboard that someone might check eventually?
The teams getting value from real-time monitoring aren’t just looking at prettier dashboards. They’re structuring workflows around automatic alerts that drive action. Critical vulnerability detected less than seven days ago and not yet remediated or POA&M’d? That should automatically escalate. System diagram no longer matches actual infrastructure? Someone should be notified immediately, not during the next quarterly review.
This is the difference between monitoring theater and actual continuous authorization. Monitoring theater looks good in demos. Actual continuous authorization changes how your team works.
What to Look for When Evaluating Solutions
If you’re evaluating platforms for CSRMC readiness, here are the questions that tend to separate architectural approaches:
- On data flow: Can data move automatically between different compliance functions, or does everything require manual export-import cycles? When vulnerability scan results come in, do they automatically flow into POA&M management and control assessment, or do you copy-paste?
- On evidence: Is evidence collected from actual system state, or is it documentation about system state? When a control requires proof of configuration, does the platform pull actual configuration data from your systems or ask you to describe your configuration in a form?
- On integration: Does the platform connect to your actual security tools—vulnerability scanners, asset management, ticketing systems—or does it just import static reports? Can it work alongside your existing GRC systems or does it demand wholesale replacement?
- On flexibility: Does the platform support both traditional RMF and CSRMC workflows, or does it force you to choose? Can you operate in hybrid mode during the transition period?
- On variability: How does the platform handle Organization-Defined Parameters? Can you customize automation depth for different controls, or is it one-size-fits-all?
- On reciprocity: How do you share completed assessments across your organization? Can teams actually find and reuse each other’s work, or is sharing theoretical?
These aren’t gotcha questions—they’re practical concerns that determine whether a platform will actually support continuous authorization or just claim to.
[If you’re currently evaluating platforms or trying to plan your CSRMC transition, reach out and we can talk through your specific situation.]
How We’re Approaching This
I spent nine years as an ISSO at a federal agency, living these exact problems. The platform we built—RiskForce Orchestrator—was designed specifically to solve them, which is why we were excited to contribute to the DoW CIO’s RFI in summer 2025. The alignment between what CSRMC asks for and the problems we’ve been working on isn’t coincidental.
Our architecture centers on what we call Live Chains—continuous data synchronization across all compliance functions. When your vulnerability scanner detects new assets, they’re automatically discovered. When you add assets to inventory, system diagrams can regenerate. When diagrams update, documentation updates. When documentation changes, controls update to reflect new evidence. This isn’t workflow automation with manual steps between each phase—it’s genuine continuous data flow.
We integrate with Nessus (which functions as ACAS in DoW environments) so vulnerability data feeds directly into the platform. We export in eMASS-compatible formats because we understand you’re not replacing legacy systems overnight. We handle reciprocity through organizational-level risk assessments and an approved products list that every system owner can access with a single click.
The platform supports both traditional RMF and CSRMC workflows because we know the transition will take years. You can use it as a standalone GRC system or as a continuous monitoring layer sitting alongside eMASS. We’re purpose-built for federal compliance—not a generic GRC platform adapted to government requirements.
But here’s the real point: continuous authorization requires architectural decisions about how data flows, how evidence is collected, and how different compliance functions stay synchronized. Whether you choose Orchestrator or another platform, make sure you’re evaluating the architecture, not just the marketing.
Moving Forward
CSRMC represents a significant shift in how DoW thinks about cyber risk management. The move from point-in-time authorization to continuous authorization, from checkbox compliance to critical controls focus, from siloed security teams to integrated DevSecOps—these aren’t small adjustments. They’re fundamental changes that will require most organizations to rethink their tooling, their workflows, and their approach to compliance.
The good news is that the transition period gives you time to plan. You don’t have to switch everything over tomorrow. But you do need to start thinking now about what continuous authorization will require from your systems, your team, and your compliance platform.
If you’re a commercial company or federal contractor seeing RMF and CSRMC requirements appear in your contracts for the first time, start with the basics. Understand what continuous authorization actually means for your specific systems. Evaluate what evidence collection will look like. Figure out which controls apply to your environment and how ODPs affect your implementation.
If you’re a government program office planning CSRMC adoption, think about the integration challenge first. How will data flow from your security tools into your compliance platform? How will you maintain that integration over time? What does continuous monitoring actually look like in your environment versus what the policy documents describe?
The teams that will succeed in the CSRMC era aren’t necessarily the ones with the biggest budgets or the most sophisticated tools. They’re the ones who understand that continuous authorization is fundamentally about maintaining accurate state, and they choose architectures that support that goal.
Ready to explore what continuous authorization looks like for your specific environment?
We offer a free 30-day trial for commercial organizations and federal contractors. No elaborate onboarding process—you can start testing with your actual systems and see how continuous monitoring works in practice.
For government programs, we’re Platform One with Awardable, and we’re interested in discussing what your specific CSRMC implementation will require. Different agencies will approach this differently—let’s talk about what makes sense for your environment.
Contact us: contact@riskforce-llc.com