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When the Cybersecurity and Infrastructure Security Agency (CISA) adds a vulnerability to its Known Exploited Vulnerabilities (KEV) Catalog, a Federal Civilian Executive Branch (FCEB) agency must remediate that vulnerability by the due date shown for the catalog entry. That obligation comes from Binding Operational Directive (BOD) 22-01. CISA’s FY 2025 FISMA evaluation guide summarizes the timing categories as six months for vulnerabilities added in 2021 or earlier and two weeks for vulnerabilities added after 2021, but the current catalog entry’s stated due date controls.
The directive applies to FCEB agencies, not every public-sector or private organization. CISA strongly encourages other organizations to prioritize KEV vulnerabilities, but that recommendation is different from a binding BOD requirement.
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What a KEV addition means
The KEV Catalog is CISA’s living list of vulnerabilities for which there is evidence of exploitation and which pose significant risk to the federal enterprise. A listing is therefore an exploitation and risk signal, not simply another ranking based on a severity score.
CISA has used dated alerts to explain why particular vulnerabilities were added, including evidence that attackers were actively exploiting them. The catalog can change as CISA adds entries, updates information, or maintains dates. Agencies should treat the live entry as the authoritative place to confirm the vulnerability, its date, and its remediation deadline.
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KEV is not the same as a severity list
A vulnerability can have a high or critical severity score without appearing in KEV, and a KEV listing carries a distinct operational implication: exploitation has been observed or otherwise established to CISA’s standard for inclusion. The catalog’s purpose is to focus defensive action on vulnerabilities that present demonstrated, material risk.
Historical scale is not a current count
When the catalog was initially published in 2021, CISA said it included approximately 200 vulnerabilities from 2017 through 2020 and about 90 vulnerabilities from 2021. Those figures describe the original publication and should not be used as the catalog’s current size.
Who is legally covered by BOD 22-01?
BOD 22-01 is binding for Federal Civilian Executive Branch agencies. In practical terms, an organization must first determine whether it is an FCEB agency before treating the directive’s KEV deadlines as a mandatory federal requirement for its systems.
| Organization | How the KEV requirement applies |
|---|---|
| FCEB agency | BOD 22-01 requires remediation of applicable KEV vulnerabilities by the due date assigned to each catalog entry. |
| State, local, tribal, or territorial government | BOD 22-01 does not bind these governments. CISA encourages timely KEV remediation, but that encouragement is not a BOD mandate. |
| Private organization | BOD 22-01 does not directly impose the FCEB deadline. CISA recommends prioritizing KEV vulnerabilities as part of vulnerability management. |
The distinction matters when writing policy, assigning accountability, or communicating with executives. Saying that every government agency is legally subject to BOD 22-01 overstates the directive. Saying that non-FCEB organizations should ignore KEV would understate CISA’s recommendation.
What deadline applies?
CISA’s FY 2025 FISMA evaluation guide summarizes BOD 22-01’s deadline categories this way:
| KEV addition period | Deadline category summarized by CISA | How to use the figure |
|---|---|---|
| Added in 2021 or earlier | Six months | Use the current catalog entry and directive to confirm the actual due date; do not recalculate a historical date from this summary. |
| Added after 2021 | Two weeks | Use the due date displayed for the current entry rather than assuming every later entry has an identical calendar interval. |
These intervals are a guide to the deadline categories, not a substitute for checking the live record. Catalog content and dates are maintained over time, and the entry’s assigned due date is the operational date an agency must meet.
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Why the current entry matters
The six-month and two-week figures are useful for understanding the policy’s structure, but they do not authorize an agency to postpone action until a calculated date. An agency should record the current entry’s due date, preserve the date and version of the information it used, and follow the controlling version of BOD 22-01 and current agency policy.
What an FCEB agency must do
The binding requirement is straightforward: remediate the listed vulnerability on affected agency systems by the catalog entry’s due date. The available CISA material does not prescribe one universal asset-discovery, change-management, reporting, waiver, or escalation workflow. Agencies must use their own approved processes while satisfying the deadline.
1. Confirm coverage
Determine that the organization is an FCEB agency covered by BOD 22-01. If responsibility is shared with another department, bureau, contractor, or service provider, establish which component owns the affected system and who can authorize remediation. The directive’s scope question should be answered before communicating a deadline as a legal obligation.
2. Read the complete KEV entry
Open the current catalog record and capture the vulnerability identifier, affected product or technology, date added, remediation action described by CISA, and assigned due date. Do not rely on a news summary, an old export, or a severity score alone. The live record is necessary because CISA maintains the catalog over time.
3. Identify affected agency systems
Map the catalog entry to the agency’s own technology inventory, applications, appliances, cloud services, and managed environments. The cited directive summaries establish the remediation deadline but do not specify a single mandatory discovery method. Use the agency’s authorized inventory and vulnerability-management controls, and document systems that are affected, not affected, or still being assessed.
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Apply the remediation described for the entry, or otherwise remove the vulnerable condition using an agency-approved technical change. “Remediate” should not be reduced automatically to installing a particular vendor patch: the appropriate action depends on what CISA specifies and on the system’s technology and operating constraints. Validate that the vulnerable condition is actually addressed across every affected instance.
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5. Keep evidence of completion
Retain the records required by the agency’s normal security, configuration, and FISMA processes. Evidence might include approved change records, system-owner confirmation, validation results, or updated inventory data, but the supplied CISA summaries do not establish one mandatory evidence format. The purpose is to demonstrate that the agency met the catalog deadline using its governing procedures.
6. Recheck the catalog and directive
Because KEV is a living catalog, continue monitoring for updates and new additions. Reconfirm the entry and deadline when a remediation plan is opened, when a change is scheduled, and when completion is recorded. Also consult the current full directive and agency policy for any requirements not addressed in the short summaries.
What “remediate” requires in practice
BOD 22-01’s central command is time-bound remediation, but the technical action can differ by vulnerability. An agency may need to install a security update, upgrade a component, remove an exposed service, change a configuration, disable a vulnerable feature, replace an unsupported system, or apply another control that eliminates the vulnerable condition. The correct action is the one consistent with the KEV entry and the agency’s approved engineering and security procedures.
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Systems that cannot be changed immediately
Operational constraints do not erase the published due date. If a system cannot be changed during normal operations, the agency should use its established change, risk-acceptance, and continuity processes while consulting the current directive and internal policy. The available CISA material does not establish a general extension, waiver, or alternate deadline, so an article should not promise that one exists.
Third-party and hosted systems
An agency remains responsible for understanding whether its systems are affected even when a contractor, cloud provider, or managed-service provider performs the technical work. Contract terms and agency policy determine how evidence and responsibilities are handled; BOD 22-01’s summarized requirement remains remediation by the catalog deadline for covered agency systems.
What the directive does not establish in the available summaries
The cited CISA material supports the scope, purpose, and deadline requirement, but it does not provide enough detail to state a universal process for the following items:
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- A standard extension or waiver procedure for missing a KEV deadline.
- A single reporting form, dashboard, or escalation chain that every FCEB agency must use.
- A mandated asset-discovery tool or vulnerability scanner.
- A single change-management sequence for every technology environment.
- A particular commercial security product or service.
Agencies should consult the current full text of BOD 22-01, subsequent CISA instructions, and their own policies before publishing requirements in these areas. Treating an unverified practice as a government-wide mandate can create inaccurate compliance advice.
How non-FCEB organizations should interpret KEV
State, local, tribal, and territorial governments, as well as private organizations, are outside BOD 22-01’s binding scope. CISA nevertheless strongly urges all organizations to reduce exposure to cyberattacks by prioritizing timely remediation of KEV vulnerabilities within their vulnerability-management practices.
For these organizations, KEV can serve as a risk-prioritization input: a listed vulnerability has an exploitation signal and should receive attention alongside business impact, exposure, compensating controls, and operational constraints. That is a sound security practice, but it should be described as CISA guidance rather than as a federal directive imposed on the organization.
A practical decision checklist for agency teams
- Scope: Is the organization an FCEB agency covered by BOD 22-01?
- Record: What is the current KEV entry, including its date added and assigned due date?
- Exposure: Which agency systems, services, products, and environments match the entry?
- Action: What remediation does the entry call for, and which approved technical change will remove the vulnerable condition?
- Ownership: Which system and service owners are accountable for completion?
- Validation: What agency-approved evidence will show that affected instances were remediated?
- Currency: Has the team checked the live catalog and current directive before closing the work?
This checklist is an operational way to organize work, not a claim that BOD 22-01 prescribes these exact steps or documents.
Common mistakes to avoid
Calling every KEV a “critical-severity” vulnerability
KEV inclusion indicates known exploitation and significant federal risk. It is not merely a synonym for a particular numerical severity rating.
Applying the FCEB deadline to everyone
The two-week and six-month categories summarize the FCEB requirement. They do not turn BOD 22-01 into a mandate for state, local, tribal, territorial, or private organizations.
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Using an old due date
A copied spreadsheet or archived article may not reflect the maintained catalog. Confirm the current entry and its date before setting or communicating a deadline.
Confusing a recommendation with an enforceable rule
CISA’s advice to other organizations is important, but it should be labeled as guidance. Only FCEB agencies are within the binding scope described by BOD 22-01.
Inventing an exception process
The available summaries do not establish a universal waiver, extension, reporting, or escalation mechanism. Refer to the current directive and agency policy instead of presenting an assumed process as fact.
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Traditional vulnerability programs often sort work by severity, asset criticality, or scanner output. A KEV addition adds evidence that attackers are exploiting a weakness in the real world. For an FCEB agency, that evidence is paired with a mandatory remediation date, converting a risk signal into a time-bound compliance task.
The result is a prioritization rule with two parts: confirm whether the agency is covered, then meet the due date for every affected system. The agency’s internal tools, approvals, and technical controls can vary, but the deadline obligation does not disappear because the environment is complex.
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