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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 assigned to the catalog entry under Binding Operational Directive 22-01 (BOD 22-01). The current catalog entry and the controlling directive are the authority for the date; do not substitute a date calculated from a general summary.
CISA’s FY 2025 FISMA evaluation guide summarizes two timing categories: six months for entries added in 2021 or earlier, and two weeks for entries added after 2021. Those are summary categories, not a replacement for checking the individual entry. BOD 22-01 is binding on FCEB agencies, not on state, local, tribal, territorial, or private organizations.
What the KEV requirement means in practice
The KEV Catalog is CISA’s living list of vulnerabilities for which exploitation is known and which pose significant risk to the federal enterprise. A listing therefore signals more than a high vulnerability score: it is an indication that attackers are exploiting the weakness or that CISA has credible evidence of exploitation. For an FCEB agency, the operational consequence is a remediation obligation tied to the catalog entry’s due date.
“Remediate” is the controlling outcome in the material available for BOD 22-01. The sources do not prescribe one universal patching tool, change-control sequence, scanner, compensating-control format, or evidence package. Agencies must use their own authorized processes to reach the required outcome and should consult the current full directive and agency policy for procedural details.
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Which organizations are covered
| Organization | Effect of BOD 22-01 | How to describe CISA’s guidance |
|---|---|---|
| Federal Civilian Executive Branch (FCEB) agency | Remediation of a KEV entry is required by the due date assigned to that entry. | The directive is binding for this group. |
| State, local, tribal, or territorial government | The directive itself does not impose the FCEB requirement. | CISA urges timely KEV remediation as a vulnerability-management practice, but that recommendation is not a BOD mandate. |
| Private organization | The directive itself does not impose the FCEB requirement. | CISA urges organizations to prioritize timely remediation, while leaving the organization’s legal obligations to other applicable authorities and contracts. |
Scope is the first decision point. An agency or organization should not label a KEV deadline a federal mandate unless it is discussing an FCEB agency covered by BOD 22-01. CISA’s August 12, 2025 alert makes this distinction explicit: “Although BOD 22-01 only applies to FCEB agencies, CISA strongly urges all organizations to reduce their exposure to cyberattacks by prioritizing timely remediation of KEV Catalog vulnerabilities as part of their vulnerability management practice.”
How the remediation deadlines are summarized
CISA’s FY 2025 FISMA evaluation guide (2025) summarizes BOD 22-01 timing as follows:
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| Catalog entry timing | Summary deadline in the FY 2025 guide | What the agency should use operationally |
|---|---|---|
| Added in 2021 or earlier | Six months | The due date shown on the current KEV entry and any controlling directive language. |
| Added after 2021 | Two weeks | The due date shown on the current KEV entry and any controlling directive language. |
The six-month and two-week figures are useful for understanding the categories used in the evaluation guide. They are not permission to postpone checking the catalog, and they should not be used to calculate a deadline when the entry supplies an actual date. Catalog content and dates are maintained over time, so an agency should record the current entry’s due date and verify the current directive before relying on an older summary.
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The sources establish the deadline and the FCEB scope, but they do not prescribe a complete asset-discovery or change-management workflow. The sequence below separates the binding result from the internal controls an agency can use to achieve it.
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- Confirm FCEB coverage. Determine that the organization is a Federal Civilian Executive Branch agency subject to BOD 22-01. If it is not, describe the KEV action as CISA-recommended risk reduction rather than as compliance with the directive.
- Open the current KEV record. Read the individual catalog entry, including its assigned due date and the CVE identifier. Record the date and the date on which the entry was checked. Do not infer the deadline solely from the year in which the vulnerability was discovered or disclosed.
- Map the CVE to agency technology. Identify agency-owned or agency-operated systems, applications, appliances, services, and versions that contain the affected component. The directive’s core requirement is remediation; the cited material does not dictate which inventory method or scanner must be used.
- Assign an owner and a completion date before the catalog due date. Route the work through the agency’s authorized vulnerability, patch, configuration, and change-management processes. Include dependencies such as vendor fixes, maintenance windows, testing, and restart requirements in the internal plan, but do not treat those dependencies as an automatic extension of the KEV deadline.
- Apply the approved remediation. Install the vendor or agency-authorized fix, upgrade, remove the vulnerable component, or otherwise follow an approved technical path that resolves the affected vulnerability. The available sources do not define which alternative controls qualify, so agencies should rely on their current directive interpretation and policy.
- Verify that remediation reached affected systems. Use the agency’s normal validation method, such as a configuration check, authenticated scan, version check, or other approved evidence. Verify the actual systems identified in step three rather than assuming that a central deployment completed everywhere.
- Retain internal evidence and update status. Record what was affected, what action was taken, when it was completed, and how completion was verified under the agency’s records and security procedures. The available material does not establish a single CISA reporting format or escalation path, so do not claim that a particular report, waiver, or notification is required without checking the current directive and agency policy.
What the catalog addition changes about priority
KEV inclusion is an exploitation signal. CISA describes the catalog as a list of vulnerabilities with known exploitation and significant federal-enterprise risk, and its dated alerts give examples of additions based on evidence of active exploitation. That makes a KEV item different from a vulnerability that is merely present in a database or ranked by a numerical severity score.
For an FCEB agency, the listing creates a time-bound remediation task. A vulnerability can have a severe score without appearing in KEV, and a KEV item should not be deprioritized simply because its score is lower than another finding. The catalog status and assigned date are the relevant triggers for the BOD 22-01 obligation.
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What agencies should not assume about exceptions
The available sources do not establish a general extension, waiver, exception, reporting, or escalation procedure for a missed or unachievable KEV date. Do not publish or implement such a process based only on the six-month or two-week summary. Instead, consult the current full text of BOD 22-01, any superseding directive, and the agency’s own policy and legal guidance.
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Likewise, the sources do not say that a particular commercial product, scanner, endpoint agent, patch platform, or compensating-control template is mandatory. Tools can support inventory, deployment, and verification, but the requirement is tied to remediation of the listed vulnerability by the assigned date.
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How non-FCEB organizations should use KEV
State, local, tribal, and territorial governments, contractors, and private organizations can use KEV status to prioritize exposure reduction because CISA strongly urges all organizations to remediate KEV vulnerabilities promptly. That is sound risk-management guidance, but it is legally different from BOD 22-01’s enforceable scope.
A non-FCEB organization should therefore check the authorities that actually govern it: applicable laws, regulations, contracts, sector requirements, insurance conditions, and internal policy. It can adopt a KEV-based service-level target or escalation rule, but it should not describe that internal target as a BOD 22-01 requirement.
Historical context for the catalog
When CISA first published the catalog in 2021, it included approximately 200 vulnerabilities from 2017–2020 and approximately 90 from 2021. Those figures, attributed to CISA’s 2021 publication, describe the initial release and are not a current catalog count. The catalog is a living resource: entries and associated dates can change, and agencies should use the current record when making a remediation decision.
Common mistakes and the correction for each
- Calling every KEV deadline a mandate. Correct the scope: BOD 22-01 binds FCEB agencies; CISA’s recommendation to other organizations is not the directive.
- Calculating a date from the six-month or two-week category. Use the actual due date displayed on the current entry instead of treating the guide’s summary as a calendar calculator.
- Treating KEV as another severity ranking. Read inclusion as an exploitation and federal-risk signal, not merely as a score threshold.
- Assuming the directive specifies a universal workflow. The cited material establishes the remediation result, not a particular inventory, testing, deployment, or evidence tool.
- Inventing a waiver or reporting process. No such mechanics are established in the cited material; consult the current directive and agency policy before describing them.
- Using historical counts as current statistics. The 2021 publication figures are historical context, not a present-day catalog total.
A practical review checklist
- Is the organization an FCEB agency covered by BOD 22-01?
- What is the CVE identifier and current KEV entry?
- What due date is displayed on that entry?
- Which agency systems and versions are affected?
- Who owns remediation, and what internal completion date precedes the catalog deadline?
- How will the agency verify that the fix reached every affected system?
- Which current directive, agency policy, or legal authority governs exceptions, reporting, or escalation if those issues arise?
The controlling principle is simple: an FCEB agency must complete remediation by the due date on the current KEV entry. The FY 2025 guide’s six-month and two-week categories explain the timing framework, while the live catalog and current directive determine the date that governs the agency’s work.
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