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Set vulnerability remediation SLAs using exploitation evidence and asset context—not CVSS severity alone. Put known-exploited vulnerabilities on exposed, high-impact systems in the fastest response lane; assign an owner and a firm due date; and keep a finding open until the vulnerability is eliminated and closure is verified. CISA’s binding deadlines under BOD 26-04 apply to federal civilian executive branch agencies. Other organizations can use CISA’s KEV catalog and risk model as guidance, then choose deadlines that fit their obligations and risk appetite.
What should a risk-based vulnerability SLA measure?
An SLA should define how quickly the organization will assess, mitigate, remediate, and verify a vulnerability. These are related but distinct actions: a temporary control may reduce exposure while a patch is pending, but it does not necessarily eliminate the vulnerability.
For each finding, record enough information to explain both its priority and its status:
- The CVE or other finding identifier, affected asset, asset owner, and business service or data at risk.
- Whether the asset is internet-facing or otherwise reachable by likely threat actors.
- Whether the vulnerability is listed in CISA’s Known Exploited Vulnerabilities (KEV) catalog or has other credible active-exploitation evidence.
- The CVSS score and vector, where applicable, alongside exploitability, automation potential, and likely technical impact.
- Vendor-fix availability, existing controls, and confidence in detection or assessment.
- The accountable remediation owner, SLA clock start, target date, any interim mitigation, exception approval, and closure evidence.
CVSS is useful severity information, but it does not by itself describe how reachable an asset is, whether attackers are exploiting a flaw, or how much the affected service matters to your organization. FedRAMP’s 2026 rules require covered providers to adjust risk and severity using context that includes criticality, reachability, exploitability, detectability, prevalence, and mitigation. That is a useful policy-design model elsewhere, but its normative requirements apply in the FedRAMP context.
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Which signals should move a finding into a faster lane?
Use evidence about likelihood and impact together. For every finding, ask whether the asset is reachable, whether exploitation is known or practical, and what an attacker could affect. An exposed system with a known-exploited, automatable flaw and severe potential impact should not wait behind a higher-CVSS issue on an isolated, low-impact asset merely because its base score is lower.
- Exploitation: Is the CVE in KEV, or is there reliable evidence it is being exploited in the wild?
- Exposure: Is the affected asset public-facing or reachable from a likely attacker’s position?
- Exploitability: Can exploitation be automated? Is exploit code publicly available?
- Impact: Could exploitation yield partial or total control, expose sensitive data, or disrupt a critical business service?
- Risk reduction: Are existing controls effective, and is a vendor fix available?
CISA recommends that all organizations monitor KEV and prioritize listed vulnerabilities. For organizations outside the federal directive’s scope, KEV is a strong escalation signal, not a binding private-sector deadline. CISA’s implementation guidance illustrates why context matters: a vulnerability CISA determines is on a publicly exposed asset, has total technical impact, and is automatable has a three-day patching deadline in that federal example. It is not a universal SLA, and the agency makes the exposure determination asset by asset.
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How do you turn risk levels into deadlines?
There is no universal non-federal day-count table established by the guidance described here. The following is an illustrative internal policy, not a CISA or industry-mandated schedule. Treat the numbers as starting targets to validate against your staffing, maintenance windows, system criticality, contracts, and applicable regulation. Use calendar days in this example; if you choose business days instead, state that explicitly.
| Illustrative band | Typical evidence | Example target for remediation | Required handling |
|---|---|---|---|
| Emergency | Active exploitation or KEV status combined with public exposure, high business impact, or readily automatable exploitation. | Within 7 calendar days | Immediate triage; apply a safe interim control promptly if a verified fix cannot be deployed at once; escalate unresolved blockers to security leadership. |
| High | Serious potential impact and meaningful reachability or exploitability, without the full emergency combination. | Within 14 calendar days | Assign an accountable owner at triage; review any deployment blocker and compensating control. |
| Moderate | Limited exposure or impact, or lower likelihood of successful exploitation, with no stronger escalation signal. | Within 30 calendar days | Schedule remediation in a defined maintenance window and reassess if exposure or threat evidence changes. |
| Low | Low contextual impact and limited exploitability or reachability. | Within 90 calendar days | Track to a finite deadline; do not let a low band mean indefinite deferral. |
These example windows are proposed policy choices, not empirical industry averages. If your organization cannot consistently meet a target, set a realistic deadline and escalation path rather than publishing a faster SLA that is routinely missed. Where a directive, regulation, contract, or customer commitment imposes a stricter requirement, map that requirement directly to the affected assets and use the stricter deadline.
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How should you define the SLA clock and workflow?
- Set scope. Name the covered environments, asset types, cloud and software dependencies, and business owners. State whether the policy covers discovery, validation, mitigation, remediation, and verification.
- Define the clock start. Choose a consistent event, such as validated detection or receipt of a vendor advisory, and specify how quickly triage must assign a risk band and owner. Define how newly discovered exploitation or exposure changes an existing due date.
- Assign accountability. Name the team or person responsible for remediation, the asset owner who can approve operational changes, and the security role that oversees prioritization and overdue work.
- Record the decision. Capture the evidence supporting the risk band, target date, required action, and any interim measure in the vulnerability record.
- Escalate exceptions and overdue findings. Route overdue KEVs and actively exploited issues to security leadership rather than silently extending the date.
- Verify closure. Accept evidence such as a successful patch or version check, a clean authenticated rescan, a validated configuration change that eliminates the flaw, or documented decommissioning. Record who verified the result and when.
For federal civilian executive branch agencies, CISA BOD 26-04, issued June 10, 2026, establishes a binding Vulnerability Response Timeline. It supersedes and revokes BOD 19-02 and BOD 22-01. The directive considers public exposure, KEV status, exploit automation, and whether post-exploitation technical impact is partial or total; its timeline is informed by SSVC and uses calendar days. CISA’s published timeline includes asset-by-asset assessment. The three-day illustration above is not enough to reconstruct the full federal matrix, so agencies should consult the directive and implementation guidance for applicable deadlines.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How should you handle mitigation, exceptions, and verification?
Keep mitigation separate from remediation
A firewall restriction, isolation, or other temporary measure may lower risk while a patch is unavailable or unsafe to deploy. Track the measure, its owner, how it was validated, its review or expiry date, and residual-risk approval. Keep the vulnerability open until it has been eliminated and verified. FedRAMP’s 2026 rules make the distinction explicit: mitigation reduces risk and impact; remediation entirely eliminates the vulnerability.
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Make exceptions time-bound and visible
Require a named risk owner, business reason, compensating controls, expiration date, and periodic reapproval. An exception records accepted risk; it should not erase the finding from the backlog or stop its age from being reported. Reassess when exploitation evidence, exposure, asset importance, or available fixes change.
Use closure evidence that matches the fix
A ticket marked “complete” is not verification. For a patch, confirm the installed version or rescan the asset; for a configuration change, validate the effective setting; for a retired system, record its decommissioning. Preserve the evidence and assessment date so another reviewer can establish why the finding was closed.
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How can you tell whether the SLA policy is working?
Review performance by risk band rather than relying on one organization-wide average. Useful measures include the share remediated within target, overdue findings, backlog age, KEV backlog, mitigation duration, repeat exceptions, and verified-closure rate. A median remediation or mitigation time can help show trends, but it should be paired with counts and tier-level results so a large low-risk backlog does not conceal delayed emergency work.
Automation can help join asset inventory and exposure context with KEV status, assign owners and due dates, record mitigations and exceptions, and retain verification evidence. CISA recommends tools that flag or prioritize KEVs; the tool should support the policy’s decisions rather than substitute for an accountable risk owner.
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