The White House's Federal Zero Trust Strategy sets five mandatory goals for agencies to meet by the end of Fiscal Year 2024. If you're responsible for your agency's implementation, you need a structured policy document that translates those goals into enforceable requirements your teams can execute.
This template provides a working policy framework aligned with the five goals and CISA's Zero Trust Maturity Model. Customize it for your agency's mission context, then use it to drive implementation planning and track progress toward the FY24 deadline.
Purpose of the Template
You're building a formal Zero Trust Architecture implementation policy that:
- Establishes baseline requirements for each of the five White House strategy goals
- Assigns ownership and accountability across your IT security organization
- Creates measurable milestones your teams can report against
- Provides audit evidence that your agency is actively addressing the federal mandate
This isn't a high-level strategy document. It's an operational policy defining what must happen and who's responsible for making it happen.
Prerequisites
Before you customize this template, ensure you have:
Authority and stakeholder alignment. This policy requires coordination between identity management, network operations, application security, and data governance teams. Confirm you have executive sponsorship and that each functional lead understands their role in the FY24 timeline.
Current-state inventory. Document your existing authentication mechanisms, device inventory capabilities, DNS/HTTP encryption status, application architecture, and logging infrastructure. The 55 percent confidence gap cited by federal IT decision-makers often stems from incomplete visibility into current capabilities.
Risk prioritization criteria. Define how you'll prioritize systems by mission-criticality, sensitivity, and likelihood of breach. This framework drives your phased implementation plan.
The Policy Template
AGENCY ZERO TRUST ARCHITECTURE IMPLEMENTATION POLICY
Effective Date: [DATE]
Review Cycle: Quarterly
Authority: Federal Zero Trust Strategy; Executive Order on Improving the Nation's Cybersecurity
1. PURPOSE AND SCOPE
This policy establishes requirements for implementing Zero Trust Architecture
across [AGENCY NAME] in accordance with the Federal Zero Trust Strategy goals
for Fiscal Year 2024.
Scope: All information systems, applications, networks, and devices operated
by or on behalf of [AGENCY NAME], including those managed by contractors and
shared service providers.
2. IDENTITY MANAGEMENT REQUIREMENTS (Goal 1)
2.1 Single Sign-On Integration
- All mission-critical applications identified in [REFERENCE YOUR INVENTORY]
must integrate with the agency enterprise SSO service by [DATE].
- All moderate-impact applications must integrate by [DATE].
- Low-impact applications must integrate by [DATE] or document technical
constraints preventing integration.
2.2 Multi-Factor Authentication
- [Personal Identity Verification](/glossary/personal-identity-verification) credential authentication is required for
all users accessing systems categorized as [YOUR CRITERIA].
- Alternative MFA mechanisms (authenticator applications, hardware tokens)
are authorized for systems that cannot accommodate PIV authentication,
subject to approval by [ROLE/OFFICE].
- MFA must be enforced at the application level, not solely at network
perimeter.
2.3 Privileged Access Management
- All privileged accounts must be managed through the agency PAM solution
by [DATE].
- Just-in-time access provisioning is required for administrative functions
on systems processing [YOUR SENSITIVITY CRITERIA].
- Privileged session recording and monitoring is mandatory for [YOUR SCOPE].
Responsible Office: [[Identity, Credential, and Access Management](/glossary/identity-credential-and-access-management) OFFICE]
Reporting: Monthly dashboard of SSO integration status, MFA coverage by
system categorization, PAM enrollment progress.
3. DEVICE MANAGEMENT REQUIREMENTS (Goal 2)
3.1 Comprehensive Inventory
- Maintain real-time inventory of all agency-authorized devices including
endpoints, mobile devices, IoT devices, operational technology, and
cyber-physical systems.
- Inventory must include device type, operating system, assigned user or
function, network location, and compliance status.
3.2 Endpoint Detection and Response
- All endpoints must run agency-approved EDR solution with active monitoring
by [DATE].
- IoT, OT, and CPS devices that cannot support traditional EDR must be
monitored through network-based detection mechanisms.
- EDR telemetry must feed into enterprise SOAR platform for correlation and
automated response.
Responsible Office: [ENDPOINT SECURITY OFFICE]
Reporting: Weekly device inventory reconciliation; monthly EDR coverage
metrics by device category.
4. NETWORK SECURITY REQUIREMENTS (Goal 3)
4.1 DNS and HTTP Encryption
- All DNS requests must utilize [CISA Protective DNS](https://www.cisa.gov/protective-dns) or equivalent encrypted
DNS service by [DATE].
- All HTTP traffic must be encrypted using TLS 1.2 or higher.
- Legacy systems requiring unencrypted protocols must be documented in
[YOUR EXCEPTION PROCESS] with compensating controls and sunset dates.
4.2 Application Segmentation
- Each distinct application must operate in its own network segment with
enforced access controls between segments.
- Shared services (authentication, logging, monitoring) must be accessible
across segments via secure, encrypted connections that do not assume
network trust.
- Network segmentation must be implemented using [YOUR APPROACH: software-
defined networking, micro-segmentation, application-layer controls]
appropriate to each use case.
Responsible Office: [NETWORK OPERATIONS OFFICE]
Reporting: Quarterly network architecture review documenting segmentation
implementation and encryption coverage.
5. APPLICATION SECURITY REQUIREMENTS (Goal 4)
5.1 Internet-Connected Architecture
- All applications must be designed and configured to operate securely while
internet-connected.
- Minimum viable monitoring infrastructure includes [YOUR SPECIFIC CONTROLS:
web application firewalls, network detection and response, packet capture,
intrusion detection systems] appropriate to application risk level.
5.2 Continuous Testing and Vulnerability Management
- All internet-facing applications must undergo penetration testing [YOUR
FREQUENCY] by independent assessors.
- All applications must participate in [YOUR VULNERABILITY DISCLOSURE PROGRAM].
- Vulnerability remediation timelines: Critical findings within 15 days,
High within 30 days, Moderate within 90 days, or document risk acceptance
by [AUTHORIZING OFFICIAL].
5.3 Software Supply Chain Security
- All applications must maintain current [Software Bill of Materials](/glossary/software-bill-of-materials).
- [Continuous monitoring](/glossary/continuous-monitoring) for known vulnerabilities in application dependencies
is required.
Responsible Office: [APPLICATION SECURITY OFFICE]
Reporting: Monthly vulnerability remediation metrics; quarterly supply chain
risk assessment.
6. DATA PROTECTION AND LOGGING REQUIREMENTS (Goal 5)
6.1 Data Categorization and Access Control
- All data repositories must be categorized according to [YOUR CLASSIFICATION
SCHEME] by [DATE].
- Access to categorized data must be controlled through Role-Based Access
Control with least-privilege principles.
- All data access must be logged with user identity, timestamp, data
accessed, and action taken.
6.2 Enterprise Logging and SOAR
- All systems must forward security-relevant logs to the enterprise logging
platform.
- Log retention: [YOUR REQUIREMENTS based on Federal Records Act and NIST
AU family controls].
- SOAR platform must correlate security events across identity, device,
network, application, and data layers to enable automated threat detection
and response.
Responsible Office: [SECURITY OPERATIONS CENTER]
Reporting: Weekly SOAR metrics including automated response actions, mean
time to detect, mean time to respond.
7. GOVERNANCE AND ACCOUNTABILITY
7.1 Implementation Oversight
- [GOVERNANCE BODY] will review implementation progress monthly.
- Milestone delays exceeding [YOUR THRESHOLD] require escalation to [EXECUTIVE
LEVEL].
7.2 Risk Exceptions
- Exceptions to this policy require written justification, compensating
controls, and approval by [AUTHORIZING OFFICIAL].
- All exceptions must include remediation plan with target completion date.
7.3 Continuous Improvement
- This policy will be reviewed quarterly and updated based on implementation
lessons learned, emerging threats, and federal guidance updates.
How to Customize It
Replace bracketed placeholders with your agency-specific information: office names, system inventories, dates, approval authorities, and technical approaches.
Adjust timelines based on your current-state assessment. If you're starting from low SSO adoption, plan a phased rollout by system criticality. If you already have strong identity management but weak device visibility, allocate more aggressive timelines to Goal 2.
Define your prioritization criteria explicitly. "Mission-critical" means different things at different agencies. Document the specific factors you're using: systems processing CUI, systems supporting specific mission functions, systems with external access, or whatever framework your leadership has endorsed.
Specify your technical approaches where the template says "YOUR APPROACH." The White House strategy is deliberately technology-neutral. Your policy should name the specific platforms, tools, and architectures your teams will use.
Align reporting frequencies with your governance cadence. If your CISO briefs leadership monthly, your reporting requirements should generate fresh data on that cycle.
Validation Steps
Before you publish this policy:
Legal and policy review. Confirm alignment with your agency's existing information security policies, Federal Information Security Modernization Act obligations, and any agency-specific statutory requirements.
Technical feasibility review. Have each responsible office confirm that the requirements are achievable with current resources or identify gaps requiring budget requests.
Dependency mapping. Validate that your timeline accounts for dependencies between goals. You can't implement effective application segmentation (Goal 3) until you have comprehensive device inventory (Goal 2).
Exception process alignment. Ensure your risk exception process integrates with existing Authority to Operate and continuous authorization workflows.
Stakeholder signoff. Obtain formal commitment from each responsible office before you publish. The confidence gap among federal IT decision-makers often stems from policies that land without the capacity to execute them.
After publication, your first quarterly review should assess whether your milestones are realistic. The FY24 deadline is fixed, but your internal phasing can adjust based on what you learn in the first 90 days of implementation.
