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Why the Same Old Bugs Keep Getting Exploited: CISA’s Secure-by-Design Wake-Up Call

Recurring software flaws are not just a customer patching problem. CISA’s Secure-by-Design effort asks manufacturers to prevent vulnerability classes and support products transparently, while distinguishing voluntary guidance from requirements for federal agencies.

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The same classes of software vulnerabilities keep returning because they can be repeated across products—and because fixes applied after release leave customers carrying much of the risk. CISA’s Secure-by-Design message asks manufacturers to prevent more of these flaws through product design, development, maintenance, and leadership, rather than treating customer patching as the whole answer. It is guidance and a voluntary pledge, not a new law binding every software maker.

Why do the same old bugs keep getting exploited?

Many incidents involve recurring vulnerability classes, not just one-off coding mistakes. SQL injection and memory-safety weaknesses are examples highlighted in CISA’s Secure-by-Design materials. If a product’s design or development process repeatedly allows a class of flaw, individual fixes may close known openings without preventing similar ones from appearing elsewhere.

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That does not mean every repeated vulnerability has the same cause, or that manufacturers are always negligent. It does mean that fixing a class of weakness systematically can be more durable than relying on customers to discover, patch, configure around, or otherwise absorb risk after release. CISA and FBI’s January 17, 2025 alert put the emphasis on reducing customer risk by prioritizing security throughout product development.

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What does secure by design mean?

Secure by Design is a shift in responsibility: manufacturers should treat customer security outcomes as part of building and supporting a product, not as a problem that begins only when a vulnerability is disclosed. CISA’s three principles, jointly developed by 17 global cybersecurity agencies, are to take ownership of customer security outcomes, embrace radical transparency and accountability, and build the organizational structure and leadership needed to deliver those goals.

In practice, that means making security decisions across the product lifecycle. Leadership must provide the priorities and structures that support secure engineering; development teams need ways to prevent and detect recurring weaknesses; and product teams need clear processes for disclosing and responding to vulnerabilities. Customers still need to manage their environments and apply updates, but the framework rejects leaving them to compensate for preventable product weaknesses alone.

What is CISA asking software companies to do?

Prevent vulnerability classes earlier

CISA’s February 11, 2025 buffer-overflow alert recommends using memory-safe languages for new software where feasible, alongside safer development practices, automated safeguards, static analysis, and code review. Memory-safe languages can help prevent certain memory-safety errors, but the alert’s recommendations are broader than a language choice: they include engineering controls and review processes that reduce the chance of vulnerabilities reaching customers.

The alert cites the Android team’s 2019 transition to memory-safe languages for new code as an example. That is a dated example, not a claim that every product or codebase can be migrated in the same way. Feasibility depends on a product’s architecture, existing code, and development needs.

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Make vulnerability handling accountable and transparent

The same February 11, 2025 alert calls for accurate and timely CVE reporting, appropriate CWE classification, vulnerability disclosure programs, and product security incident response teams. These practices help identify and communicate weaknesses, give them useful classifications, and establish who handles reports and product security incidents.

Fix exploited components before release, then support customers

In its January 2025 joint Product Security Bad Practices guidance, CISA and the FBI state: “Software manufacturers should patch all known exploited vulnerabilities within software components prior to release.” If a component vulnerability is added to CISA’s Known Exploited Vulnerabilities (KEV) catalog later, the guidance recommends providing a no-cost patch within 30 days after a patch for the component becomes available. That is a conditional recommendation for manufacturers, not a universal statutory deadline.

If a manufacturer determines that a component vulnerability cannot be exploited in its product, the joint guidance says it should publish written documentation explaining why. This makes the basis for that risk decision visible rather than leaving customers to guess whether the issue was assessed.

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What is the difference between CISA’s pledge, its guidance, and a requirement?

These are related efforts, but they do not impose the same obligations. The Secure-by-Design Pledge is voluntary and focused on enterprise software products and services. The joint bad-practices guidance gives manufacturers recommended practices. Binding Operational Directive 22-01, by contrast, requires Federal Civilian Executive Branch (FCEB) agencies to remediate vulnerabilities in the KEV catalog by assigned due dates.

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Program or policy Voluntary or binding? Who it addresses Action and timeframe
Secure-by-Design Pledge (CISA, 2024) Voluntary Manufacturers of enterprise software products and services Describes one-year goals, including showing progress on reducing default-password exposure and measurable progress against at least one vulnerability class. Using parametrized queries consistently to prevent SQL injection is one example.
Product Security Bad Practices (CISA and FBI, January 2025) Voluntary manufacturer guidance Intended for manufacturers supporting critical infrastructure; all software manufacturers are strongly encouraged to avoid the listed practices Recommends practices including patching known exploited component vulnerabilities before release and, if the component flaw enters KEV later, a no-cost patch within 30 days after a component patch is available.
Binding Operational Directive 22-01 Binding directive for agencies in scope Federal Civilian Executive Branch agencies Requires remediation of KEV vulnerabilities by the assigned due dates.

The KEV catalog is a living list based on evidence of active exploitation. CISA urges organizations outside BOD 22-01’s scope to prioritize remediation too, but that recommendation does not make the directive binding on every company.

What should customers take from the wake-up call?

Secure by Design does not remove the need for customers to apply updates or manage their own systems. It changes what they should expect from manufacturers: fewer preventable weaknesses reaching products, clearer vulnerability reporting, and accountable support when flaws are found. The practical test is whether a company can show progress against specific risks and explain how its product security practices protect customers—not simply whether it has adopted the phrase.

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