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Comply Defense
Category: Classified Information Management

Commercial Solutions for Classified

Also known as: CSfC, Commercial Solutions for Classified Program
Simply put

Commercial Solutions for Classified (CSfC) is a program run by the National Security Agency (NSA) that allows commercial off-the-shelf (COTS) products to be combined to protect classified information. Instead of relying only on custom government-built equipment, CSfC lets organizations layer two or more approved commercial products to build a secure solution more quickly. It is part of NSA's broader commercial cybersecurity strategy that draws on industry technology and innovation.

Formal definition

CSfC is an NSA commercial cybersecurity strategy and process that enables the protection of classified information using an end-to-end architecture built from two or more commercial off-the-shelf (COTS) products combined into a layered solution. It leverages industry innovation to deliver protection for National Security Systems (NSS) through an NSA-industry partnership. As described in the available evidence, CSfC centers on the composed, layered use of COTS components rather than purpose-built government cryptographic equipment; readers should consult current NSA CSfC Capability Packages and component/solution listing requirements for the specific product eligibility, layering, and registration/approval processes, which are not detailed in the evidence provided here.

Why it matters

Historically, protecting classified information depended heavily on purpose-built government cryptographic equipment, which could be costly and slow to field. CSfC represents NSA's strategy to draw on commercial off-the-shelf (COTS) technology and industry innovation, enabling organizations to compose approved commercial products into layered solutions that protect classified information more quickly. For programs operating National Security Systems (NSS), this matters because it can shorten the path to fielding secure capabilities while still aligning with NSA-defined requirements.

The central discipline of CSfC is layering: the strategy relies on combining two or more COTS products so that the compromise of any single component does not by itself expose classified data. This is a meaningfully different assurance model from relying on a single government-built device, and it places responsibility on implementers to build the architecture correctly according to NSA guidance rather than assuming that individual commercial products are inherently sufficient on their own.

A common and consequential mistake is treating CSfC as interchangeable with other cybersecurity authorities or assuming that using approved commercial products alone confers approval. CSfC operates within the National Security Systems context and follows NSA's specific processes; it is distinct from FedRAMP authorization, from FISMA-based civilian requirements, and from CUI-focused frameworks. Selecting listed components does not substitute for the required architecture, layering, and approval steps, and readers should not equate product eligibility with an approved, operational solution.

Who it's relevant to

National Security System (NSS) owners and program managers
Organizations responsible for systems that store, process, or transmit classified information may use CSfC as a route to field protective solutions built from commercial products. They should verify current NSA requirements before assuming a layered COTS architecture meets their program's obligations.
Information system security managers and security architects
Personnel who design and maintain secure architectures for classified environments need to understand the layered, two-or-more-COTS-product model at the heart of CSfC and consult NSA Capability Packages to implement the required layering and approval steps correctly.
Government contractors and industry partners
Vendors and integrators working within the NSA-industry partnership contribute the commercial technology and integration expertise that CSfC depends on. They should confirm product listing status and solution requirements against current NSA guidance rather than relying on general eligibility assumptions.
Authorizing officials and assessors in classified environments
Those responsible for evaluating or approving systems handling classified information should distinguish CSfC's process from other authorization regimes and recognize that product selection alone does not constitute an approved solution. The specific approval and registration processes should be confirmed against current NSA CSfC materials.

Inside CSfC

Layered Encryption Architecture
CSfC generally relies on two independent, composed layers of commercial encryption to protect classified data, so that the compromise of a single layer does not expose the protected information. The specific composition depends on the applicable Capability Package.
Capability Packages (CPs)
NSA publishes Capability Packages that describe approved configurations for particular use cases, such as mobile access, campus wireless, or data-at-rest solutions. Practitioners should confirm the current version of the relevant CP against NSA's official releases, as these are revised over time.
NSA Program Ownership
CSfC is a program owned and maintained by the National Security Agency, not by NIST, the FedRAMP PMO, or the DoD CIO. This distinguishes it from control-baseline frameworks like NIST SP 800-53 and from cloud authorization programs like FedRAMP.
Components List
CSfC solutions are generally built from commercial products that appear on the NSA CSfC Components List and meet specified selection criteria. Inclusion on the list and eligibility criteria can change, so the reader should verify current entries against NSA's published list.
Registration and Approval Process
Organizations typically register CSfC solutions with NSA and follow the applicable Capability Package requirements before the solution is used to protect classified information. This is a program-specific process distinct from an RMF Authority to Operate.
Use of Commercial (Non-GOTS) Products
A defining feature is the use of commercially available products, properly composed and configured, as an alternative to traditional government-off-the-shelf (GOTS) Type 1 cryptographic solutions for protecting classified data.

Common questions

Answers to the questions practitioners most commonly ask about CSfC.

Does CSfC mean the same thing as a traditional government-furnished cryptographic (Type 1) solution?
No. CSfC is an approach that layers commercial off-the-shelf products to protect classified information, whereas traditional Type 1 solutions rely on NSA-developed or NSA-controlled cryptographic equipment. These are distinct paths, and treating them as interchangeable is a common error. CSfC is intended to offer an alternative that leverages commercial technology, but it does not automatically carry the same handling, approval, or lifecycle characteristics as a Type 1 solution. Readers should confirm the current requirements and approved use cases against NSA's authoritative CSfC guidance.
If a product appears on the CSfC Components List, does that mean my solution is automatically approved to protect classified data?
No. Inclusion of a component on the CSfC Components List indicates the product has met the applicable component requirements, but it does not by itself authorize an operational solution. A CSfC solution generally must be built in accordance with the relevant Capability Package, integrate approved components correctly, and go through the applicable registration and approval process before operation. Component listing and solution approval are separate matters, and the distinction is one experts insist on. Verify the current process in NSA's published CSfC materials.
What role do Capability Packages play when implementing a CSfC solution?
Capability Packages are the design guidance that describe how to combine approved commercial components into a layered architecture for a given use case. In most implementations, they specify the required configuration, layering, and security requirements that an implementer follows. Because Capability Packages are revised over time, implementers should build against the applicable current version and confirm any updates against NSA's authoritative CSfC publications rather than relying on a previously downloaded copy.
How does the CSfC registration process relate to authorization to operate the system?
CSfC registration is a distinct step from the authorization decision made under the applicable risk management process for the system. Registering a solution generally documents that it aligns with the relevant Capability Package and uses approved components, but the system still typically requires its own authorization consistent with the governing framework and the responsible authorizing official's determination. Confusing registration with system authorization is a common mistake; confirm the specific sequencing and responsibilities against current official guidance.
Who is responsible for the ongoing security of a fielded CSfC solution?
Responsibility for a fielded CSfC solution generally rests with the implementing organization, which typically must maintain the solution in accordance with the applicable Capability Package, keep components current, and address changes to the approved configuration. As with any solution protecting sensitive or classified information, approval is not a one-time event, and continuous monitoring and maintenance obligations generally continue throughout the lifecycle. Confirm the specific roles, monitoring expectations, and reporting requirements against current NSA and organizational guidance.
What should an implementer verify before relying on CSfC guidance or component listings?
Because Capability Packages, the Components List, and associated processes are revised over time, implementers should verify that they are working from the current, authoritative NSA CSfC publications rather than cached or third-party summaries. It is also prudent to confirm that the intended use case is within the scope of an available Capability Package and that any organization-specific or program-specific requirements are addressed. This entry does not cover implementation, contractual, or configuration specifics, which must be confirmed against current official sources.

Common misconceptions

CSfC approval is the same as an Authority to Operate (ATO) under the Risk Management Framework.
CSfC registration and approval through NSA is a distinct process from RMF authorization. A system may still require an ATO from its Authorizing Official, and CSfC approval does not by itself satisfy or replace that authorization. The two should not be conflated.
Any commercial encryption product can be used to build a CSfC solution.
CSfC solutions generally must be built from products that meet NSA's selection criteria and, where applicable, appear on the NSA CSfC Components List, and they must be composed according to the relevant Capability Package. Arbitrary commercial products do not qualify.
CSfC and FedRAMP or NIST-based compliance are interchangeable protections for classified data.
CSfC is an NSA program specifically oriented toward protecting classified information using layered commercial encryption. FedRAMP addresses cloud service authorization for federal systems, and NIST publications provide control baselines; none of these automatically satisfies CSfC requirements, and each is maintained by a different authority.

Best practices

Identify and use the current version of the applicable NSA Capability Package for your specific use case, and re-verify it against NSA's official releases rather than relying on a cached or prior version.
Confirm that each product in the proposed architecture is eligible under NSA's selection criteria and, where applicable, currently appears on the NSA CSfC Components List before committing to a design.
Preserve genuine independence between the two encryption layers so that the compromise of one layer does not defeat the overall protection, as intended by the layered architecture.
Treat CSfC registration and approval as separate from RMF authorization, and coordinate with the Authorizing Official to address any required ATO obligations distinctly.
Document the composition, configuration, and registration steps to support ongoing compliance and to accommodate future revisions to the relevant Capability Package or Components List.
Verify all program-specific requirements, criteria, and processes against current NSA official sources before deployment, since CSfC guidance and product eligibility evolve over time.