CISA Published the Logging Reference Architecture — and Contractor-Operated Systems Are In Scope
CISA published the Logging Reference Architecture on August 20, 2026, implementing OMB Memorandum M-26-14, which rescinded M-21-31 and put federal civilian agencies on a maturity clock for how they log, retain, and produce network data. The memorandum reaches systems operated “by third parties on the agency’s behalf” — so contractor-run systems are inside the agency’s plan, and the obligation will arrive through contract terms rather than the memo itself.
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