In an era characterized by escalating cybersecurity threats, rapidly evolving technological landscapes, and heightened regulatory demands, organizations face significant pressure to modernize their Governance, Risk, and Compliance (GRC) practices. The federal government is also pivoting toward automation, with Policy-as-Code (PaC) becoming a foundational element in modern cybersecurity governance and compliance.

A critical driver accelerating this urgency is a recent executive order that explicitly underscores robust cybersecurity frameworks, continuous monitoring, and adaptive compliance strategies. In response, organizations must move toward adopting innovative solutions such as Policy-as-Code methodologies.

Aligning with the cyber EO

In June, the White House issued an executive order that directs the National Institute of Standards and Technology, the Cybersecurity and Infrastructure Security Agency, and the Office of Management and Budget to launch a pilot within one year that expresses federal cyber policy in a machine‑readable format. The same section instructs the Federal Acquisition Regulation Council to revise procurement rules so that by January 2027, agencies may buy only consumer IoT products whose Cyber Trust Mark can be parsed automatically. 

This isn’t just a technical experiment: It’s a blueprint for the future of cyber governance. This is a decisive endorsement of automation-based compliance and signals a governmentwide expectation that policy implementation must be verifiable, scalable, and code-driven.

These deadlines extend beyond federal departments. Any company that sells software, cloud services, or connected devices to the public sector will soon need to prove that its security controls are written and enforced through machine‑readable rules. The fastest and most reliable way to supply that proof is Policy-as-Code. Teams that move early will gain an advantage when the new rules shape purchasing decisions. Teams that wait risk a backlog of manual controls and a shrinking share of government business.

What is Policy-as-Code?

Policy-as-Code refers to the practice of translating governance, risk management, and compliance policies into machine-readable formats by leveraging automation, and creating a more structured, dynamic, and scalable compliance environment. Policy-as-Code removes ambiguity from interpretation and puts security policies on equal footing with infrastructure and application logic. The result is a proactive compliance governance that scales as fast as today’s threats. 

The Risk Management Framework (RMF) has long provided structured guidelines for organizations to categorize, select, implement, assess, authorize, and continuously monitor their information systems. However, traditional RMF processes often rely heavily on manual efforts, making them less responsive and increasingly prone to errors in today’s fast-paced digital environment. 

As of today:

• Release velocity has accelerated: Development teams merge code many times each day; manual assessment packages cannot keep pace.
• Architectural complexity has grown: Hybrid clouds, containers, edge devices, and software‑as‑a‑service platforms create connections too dense for spreadsheet mapping.
• Regulatory concurrency has intensified: Programs must show conformance with FISMA, FedRAMP, CMMC, the Secure Software Development Framework, multiple state privacy laws, and sector‑specific rules at the same time.

Policy-as-Code resolves these gaps because rules run continuously, update quickly, and leave a clear evidence trail. 

Strategic benefits of implementing Policy-as-Code

Organizations adopting Policy-as-Code experience several transformative benefits, positioning themselves advantageously within a highly competitive regulatory environment:

• Risk reduction: Automated enforcement minimizes risks associated with human error, improving compliance accuracy and reducing vulnerabilities.
• Audit efficiency: Immutable logs replace screenshots, shared drives, and labor‑intensive walk‑throughs.
• Operational efficiency: Automating policy enforcement streamlines processes, significantly reducing the administrative burden and enabling teams to focus on strategic tasks rather than routine compliance checks.
• Regulatory agility: When NIST updates a control catalog, teams change one file and push the update across every environment with a pull request.
• Enhanced security posture: Real-time monitoring capabilities bolster an organization’s security posture, swiftly identifying and addressing potential threats or breaches.
• Cost savings: By reducing the manual effort needed for compliance monitoring and enforcement, Policy-as-Code can lead to considerable cost reductions over time.
• Greater resilience: Codified governance reduces ambiguity and enhances organizational readiness under stress.

Making it Work: practical steps for effective implementation

To effectively adopt Policy-as-Code and maximize its benefits, organizations should consider the following structured approach:

• Comprehensive policy mapping and evaluation: Begin by evaluating every policy, regulation and policy applicable to your organization, map all the frameworks (e.g. NIST SP 800-53, ISO/IEC 27002 etc.) applicable to your organization, and assign a unique identifier to each of the mapped control. This mapping forms the foundation for robust automation.
• Select an open declarative machine-readable language: Choose a well‑supported machine-readable format — like NIST’s Open Security Controls Assessment Language (OSCAL) or Open Policy Agent (OPA) — that integrates with existing infrastructure‑as‑code (IaC), container orchestration, and pipeline tools.
• Convert prose to machine‑readable schemas: Translate Word and PDF controls into structured formats such as OSCAL.
• Integration into development pipelines: Evaluate and deploy specialized automation platforms capable of integrating seamlessly into existing DevSecOps workflows and lifecycle. These platforms should offer real-time compliance verification, automated remediation capabilities, and ensure continuous validation of compliance at every stage of the software development process, from initial coding through deployment and operation.
• Ongoing monitoring and continuous improvement: Implement robust tools for continuous compliance monitoring. Regularly review and update policy logic to accommodate evolving regulatory landscapes and cybersecurity threats.
• Automate evidence collection: Connect cloud APIs, container scanners, and endpoint telemetry to a central repository so evidence accrues automatically.
• Training and capacity building: Invest in targeted training programs to equip your teams with the necessary technical and conceptual understanding of Policy-as-Code methodologies and Git workflows, and teach developer teams regulatory vocabulary.
• Cultural alignment and leadership support: Actively cultivate a culture that values compliance automation and proactive risk management. Secure buy-in and sustained support from senior leadership to ensure smooth adoption and integration.
• Pilot and iterate: Begin with a high-priority control (e.g., encryption at rest) and run a focused pilot. Measure its effectiveness, gather stakeholder feedback, and iterate. Success here builds momentum.
• Inform and measure impact: Codified controls should feed into your broader risk dashboards and compliance reporting mechanisms, track policy coverage, mean time to remediation, audit hours saved, and defects prevented. Share results with executive stakeholders.

The road ahead

The future of cybersecurity governance clearly points toward increased automation, dynamic regulatory adaptation, and highly responsive compliance frameworks. Policy-as-Code is not merely a temporary trend but a fundamental shift in how organizations approach GRC. Soon, federal contracts may require delivery of not only human-readable SSPs but also machine-verifiable compliance packages. Audits may involve running scripts instead of reviewing PDFs. And AI-powered governance engines will cross-check deployments against codified policies in real time.

The EO’s emphasis on rules-as-code is just the beginning. The EO also sets timelines for managing AI vulnerabilities and adopting post‑quantum cryptography. Agencies must publish an AI vulnerability dataset by Nov. 1 and must transition to quantum‑resistant encryption by 2030. 

The clock is ticking. Agencies must pilot rules as code by June 2026, and suppliers must attach machine-readable security labels by January 2027. Organizations that translate policy into executable pipelines now will close vulnerabilities faster, cut assessment costs, and enter bid rooms as trusted partners. Those that wait will face manual backlogs, increased expenses, and shrinking market share once the grace period ends. Policy-as-Code is no longer experimental, but an operational and compliance imperative that will distinguish tomorrow’s security-ready organizations from everyone else.

The future of cyber and AI governance won’t be documented; it will be deployed!

Ibrahim Waziri Jr. is a principal security product manager in Microsoft’s Cybersecurity, Cloud, AI & Trust Engineering Team, a cybersecurity fellow at New America, and an adjunct professor of cybersecurity at Marymount University.

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Three teenagers and a 20-year-old woman were arrested Thursday by the U.K.’s National Crime Agency for their alleged role in cyberattacks on major retailers Marks & Spencer (M&S), Co-op, and Harrods.

The arrests, comprising British and Latvian nationals, followed sustained investigations into attacks that crippled the retailers’ operations. The NCA’s National Cyber Crime Unit detained all four at their homes and seized their electronic devices.

“Since these attacks took place, specialist NCA cybercrime investigators have been working at pace and the investigation remains one of the Agency’s highest priorities,” Deputy Director Paul Foster, head of the NCA’s National Cyber Crime Unit, said in a statement. “Today’s arrests are a significant step in that investigation but our work continues, alongside partners in the U.K. and overseas, to ensure those responsible are identified and brought to justice.”

The particular incidents that led to these arrests occurred in April, with attackers crippling the online services of Marks & Spencer, a popular retailer in the U.K. The company’s online sales channels were halted, contactless payments and click-and-collect options were disrupted, and in-store product availability suffered. The attack also resulted in the theft of customer information, including names, email addresses, and postal data. Recovery efforts began in June, with the retailer eventually restoring sections of its online business across the U.K.

Industry experts and law enforcement agencies in several countries have attributed the attacks to a cybercriminal group known as Scattered Spider. The loose-knit collective has infiltrated more than 100 businesses since 2022, hitting organizations in hospitality and gaming, manufacturing, technology and cloud services, telecommunications, retail, manufacturing, food production, insurance and financial services, media, apparel, business process outsourcing, health care, transportation and aviation, according to researchers. 

The group is allegedly also behind cyberattacks on several U.S.-based insurance companies, United Natural Foods, and aviation companies WestJet and Hawaiian Airlines. 

The group is an offshoot of The Com, a much larger grassroots network of more than 1,000 people responsible for a vast catalog of crimes, including social engineering, crypto theft, phishing, SIM swapping, extortion, sextortion, swatting, kidnapping and murder. 

All four arrested are being held on suspicion of violating the U.K.’s Computer Misuse Act, blackmail, money laundering and participating in the activities of an organized crime group.

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