Skip to main content
Comply Defense
Category: Supply Chain Risk Management

Federal Acquisition Security Council

Also known as:
Simply put

The Federal Acquisition Security Council (FASC) is a U.S. executive branch group made up of representatives from multiple agencies that works to reduce security risks in the technology and products the federal government buys. It was created by Congress in 2018 to establish a coordinated, government-wide process for deciding whether certain products or vendors pose supply chain risks. Its goal is to help protect federal information technology from vulnerabilities and exploitation.

Formal definition

The FASC is an executive branch interagency council, established by Congress in 2018 and chaired by a senior-level official from the Office of Management and Budget, responsible for coordinating a centralized, deliberative process for managing information and communications technology supply chain risk across the federal government. Its statutory responsibilities generally include facilitating information sharing among agencies and determining whether covered articles or sources present supply chain risks that may warrant removal or exclusion orders. Administrative and information-sharing support functions, including support to a supply chain risk management Task Force, are provided by a designated information sharing agency (identified in the evidence as CISA). Note that specific procedural mechanics, the scope of covered articles, and the effect of exclusion or removal orders are governed by the implementing rule and subsequent orders, which readers should verify against the current authoritative text; this entry does not cover contractor compliance obligations triggered by specific FASC orders.

Why it matters

Supply chain compromises in information and communications technology (ICT) can undermine federal systems in ways that traditional perimeter defenses do not address, because the risk is introduced through products, components, or vendors the government has chosen to acquire. Before the FASC, agencies generally lacked a coordinated, government-wide mechanism for deciding whether a particular product or source posed an unacceptable supply chain risk, which could lead to inconsistent decisions across the executive branch. The FASC was created by Congress in 2018 to establish a centralized, deliberative process for making these determinations and for sharing supply chain risk information among agencies.

For compliance officers, contractors, and authorizing officials, the FASC matters because it can serve as the source of exclusion or removal orders that affect which products and vendors may be used across federal agencies. The implementing rule published in 2021 and subsequent orders define how these determinations translate into obligations, so a FASC action is not merely advisory background, it can carry operational consequences for procurement and system authorization decisions. Readers should note that the precise effect of any given order, the scope of covered articles, and the resulting contractor obligations are governed by the implementing rule and the specific order, which must be verified against the current authoritative text.

Because the FASC's authority sits alongside, and does not replace, other risk management frameworks and suspension and debarment mechanisms, practitioners should be careful not to treat a FASC determination as interchangeable with those separate authorities. A product or vendor addressed by the FASC may also be subject to other regulatory or contractual requirements, and compliance with one process does not automatically satisfy another.

Who it's relevant to

Government contractors and suppliers
Contractors that provide ICT products, components, or services to federal agencies may be affected when the FASC issues determinations, exclusion orders, or removal orders touching their products or sources. Because such orders can trigger obligations and affect eligibility to supply the federal government, contractors should monitor FASC actions and confirm the specific requirements of any applicable order against the current authoritative text, rather than assuming a determination is purely advisory.
Federal acquisition and procurement officials
Contracting officers and acquisition personnel rely on the FASC's coordinated process to inform decisions about whether certain products or vendors present supply chain risks. This entry does not cover the detailed procurement mechanics; officials should consult the implementing rule and any relevant orders to understand how a FASC action bears on specific acquisition decisions.
Compliance officers and ISSMs
Information system security managers and compliance officers should understand where FASC authority fits relative to other supply chain risk management and system authorization requirements. A FASC determination is a distinct mechanism and does not automatically satisfy, or substitute for, other applicable frameworks, so its effect on a given system or acquisition should be assessed separately and verified against current guidance.
Agency risk and information-sharing personnel
Staff involved in interagency supply chain information sharing, including those interacting with the designated information sharing agency (identified as CISA) and the supply chain risk management Task Force, are directly engaged with FASC-supported processes. They should confirm current roles, procedures, and reporting expectations against the authoritative rule and CISA guidance.

Inside FASC

Statutory Basis (SECURE Technology Act)
The FASC was established under the Federal Acquisition Supply Chain Security Act of 2018, enacted as part of the SECURE Technology Act. Readers should verify the exact statutory citation and any subsequent amendments against the current codified text, as authorities and definitions may have been updated.
Supply Chain Risk Management Mission
The Council was created to improve executive branch coordination on information and communications technology (ICT) supply chain risks, generally facilitating information sharing and recommending governmentwide actions to address identified risks.
Recommendation Authority for Exclusion and Removal
The FASC is generally empowered to issue recommendations for exclusion orders (barring procurement of covered articles) and removal orders (removing covered articles from systems). The precise scope, thresholds, and the officials who issue binding orders should be confirmed against the governing statute and implementing regulations, as the FASC recommends while designated officials or agency heads may issue the operative orders.
Interagency Composition
The Council is composed of representatives from multiple executive branch entities responsible for acquisition, information security, and supply chain functions. The specific member agencies and any chairing arrangements should be verified against the current authorizing text, as membership provisions may differ across revisions.
Information Sharing Function
The FASC framework generally provides mechanisms for sharing supply chain risk information among federal agencies, and in some cases with non-federal entities, subject to applicable handling and disclosure limitations that a practitioner must confirm.
Relationship to Implementing Regulations
The FASC's operational details are further defined through implementing regulations and interim or final rules. Because these can be revised, the specific procedures, definitions of 'covered articles,' and process timelines described in rulemaking should be checked against the current published version.

Common questions

Answers to the questions practitioners most commonly ask about FASC.

Does the FASC issue cybersecurity control requirements like NIST SP 800-53 or NIST SP 800-171?
No. The FASC is not a control-catalog authority, and conflating it with NIST is a common mistake. NIST develops and maintains control frameworks such as SP 800-53 and SP 800-171, while the FASC is an interagency council focused on supply chain risk management for information and communications technology and services (ICTS), including sharing supply chain risk information and, where authorized, recommending exclusion or removal actions. You should not treat FASC activity as a substitute for implementing an applicable NIST control baseline; verify the specific obligations against the current authoritative text for each.
Is a FASC recommendation the same thing as a binding, government-wide procurement ban?
Not automatically. It is a mistake to equate a FASC recommendation with a self-executing prohibition. In most implementations, the FASC develops and issues recommendations regarding removal or exclusion, but the operative directive authority to issue removal or exclusion orders generally rests with designated officials or agency heads acting on those recommendations within their respective scopes. The precise procedural steps, thresholds, and effective actions should be confirmed against the current governing statute and regulation rather than assumed.
How does a FASC exclusion or removal recommendation interact with our existing FISMA or RMF authorization work?
Treat them as distinct but complementary. FISMA and the RMF govern how a given system is assessed and authorized to operate, while FASC-related actions address supply chain risk associated with specific ICTS covered articles or sources. A current Authority to Operate does not resolve a supply chain exclusion or removal concern, and neither does compliance alone guarantee security. You should coordinate acquisition, supply chain risk management, and authorization functions, and confirm how any applicable exclusion or removal action affects covered products in your environment against current official sources.
Which systems and information are within scope of FASC-related supply chain actions in our environment?
Scope generally centers on information and communications technology and services and the associated supply chain risk, and applicability can differ across federal civilian, defense, and national security systems. State, local, tribal, and territorial obligations may differ as well. Because agency-specific interpretation and tailoring apply, you should map your covered ICTS, identify which agency authorities apply to your systems, and verify the exact scope and any exemptions against the current governing regulation before acting.
What should a compliance program do when a FASC-related removal or exclusion action affects a product already in use?
In most implementations, an affected organization needs to identify where the covered article or source appears in its systems and supply chain, assess operational and mission impact, and follow the applicable agency process and timeline for removal, replacement, or any authorized waiver mechanism. This entry does not cover the specific procedural, contractual, or legal steps, which vary by agency and by the terms of the particular order; confirm required actions, deadlines, and any exception processes against the current authoritative text and your contracting authority.
How does FASC information sharing relate to CISA and to our own supply chain risk reporting?
CISA generally supports the FASC's information-sharing and analytic functions, but this entry does not establish the precise reporting channels, formats, or obligations that apply to your organization. You should determine whether and how your reporting responsibilities are defined by the agencies with which you contract, coordinate through your designated supply chain risk management points of contact, and verify current reporting requirements against official sources rather than assuming a single uniform process.

Common misconceptions

The FASC directly issues binding exclusion and removal orders on its own authority.
As generally structured, the FASC recommends exclusion and removal actions, while the authority to issue binding orders rests with designated officials or agency heads under the governing statute. Practitioners should verify who holds issuance authority and the applicable procedures in the current authoritative text rather than assuming the Council acts unilaterally.
The FASC is the same as, or a substitute for, established security control and compliance frameworks such as the RMF, FISMA, FedRAMP, or CMMC.
The FASC addresses ICT supply chain risk coordination and recommendations and is distinct from control frameworks and authorization programs. Meeting FASC-related requirements does not by itself satisfy separate obligations under FISMA, the RMF, FedRAMP, or DoD contractual requirements, and compliance with supply chain measures is not equivalent to overall system security.
FASC exclusion or removal recommendations apply uniformly and permanently across all federal, state, local, and defense contexts.
Scope, applicability, and duration depend on the governing statute and implementing regulations, and obligations for national security systems, defense systems, or non-federal entities may differ. The specific reach and whether any action is time-bound or subject to reconsideration should be confirmed against current official sources.

Best practices

Confirm the current statutory text and implementing regulations before relying on any description of FASC authorities, membership, or procedures, since these provisions may have been amended across revisions.
Distinguish the FASC's recommendation role from the issuance of binding exclusion or removal orders, and identify which official holds issuance authority for your specific situation.
Treat FASC-related supply chain requirements as separate from, not a substitute for, obligations under FISMA, the RMF, FedRAMP, or DoD contractual clauses, and track each compliance stream independently.
Verify how any exclusion or removal action defines 'covered articles' and the affected systems before assuming it applies to your procurement or infrastructure.
Coordinate with your agency's acquisition, information security, and legal or contracting personnel to interpret FASC-driven requirements, since agency-specific tailoring and implementation details may vary.
Monitor for updates to FASC rulemaking and information-sharing procedures, and confirm current handling and disclosure limitations before sharing or acting on supply chain risk information.