What Is BOD 22-01, and How to Prepare for It

Cybersecurity teams often seem stuck on a vulnerability treadmill. They face a constant, overwhelming flood of alerts, and the primary guidance has been to chase theoretical "critical" severity scores. But this approach is broken, because it prioritizes the utilization of limited resources on threats that could be exploited versus threats that are actually being exploited in the wild. This is precisely the problem CISA's Binding Operational Directive (BOD) 22-01 was designed to solve.

Instead of asking you to patch everything, this U.S. cybersecurity directive provides a simple, powerful framework for prioritization. It shifts organizations away from complex, theoretical scoring and toward a single, evidence-based list: the Known Exploited Vulnerabilities (KEV) catalog. The KEV catalog's logic is compelling: stop focusing on what could be exploited and focus on what is being exploited.

Organizations following BOD 22-01 can better direct their people and budgets to the most urgent threats, dramatically reducing real-world risk. 

While the directive is mandatory for federal agencies, BOD 22-01’s principles have quickly become the new standard for effective vulnerability management in the private sector. Adoption is more critical than ever in the face of rising cyberthreats and research showing that 55% of organizations still lack a comprehensive system for vulnerability prioritization. 

For any company in the defense supply chain, pursuing CMMC certification, or building a NIST 800-171-aligned security program, BOD 22-01 provides a practical blueprint for risk reduction. Let’s break down what you need to know about the directive’s requirements and the six steps to take to help your organization comply.

What is BOD 22-01?

At its core, BOD 22-01 is a compulsory directive from the U.S. Cybersecurity and Infrastructure Security Agency (CISA). It establishes a new baseline for how federal organizations must manage a specific, high-risk set of vulnerabilities. The directive's primary function is to require organizations to remediate flaws listed in CISA's official Known Exploited Vulnerabilities (KEV) catalog within strict, time-bound deadlines.

While BOD 22-01 is technically only mandatory for Federal Civilian Executive Branch (FCEB) agencies, its impact is far broader. It has been widely adopted as an authoritative guide for all public and private organizations, especially those in government supply chains or those seeking to mature their vulnerability management programs.

The importance of BOD 22-01 comes from its strategic shift away from theoretical scores and toward evidence-based action, which provides benefits in four key ways:

1. Shifts focus from theoretical to actual risk: Instead of just relying on CVSS (Common Vulnerability Scoring System) scores, BOD 22-01 prioritizes vulnerabilities based on hard evidence of active exploitation, based on real-world data from incident reports, threat intelligence, and offensive cybersecurity operations.
2. Provides an authoritative list of threats: The KEV catalog is a single, clear source of truth that allows teams to focus their limited security resources on the flaws that pose an immediate and proven threat.
3. Creates a pass/fail benchmark: The KEV catalog is a list with non-negotiable deadlines. This provides a simple, measurable benchmark for performance: was the specific, high-risk vulnerability remediated by the CISA-mandated due date? Yes or no.
4. Directly supports major compliance frameworks: The principles of BOD 22-01 are a foundational component for programs like CMMC and NIST.

The Three Core Directives of BOD 22-01

BOD 22-01 is built on three core actions:

1. Adopting and Operationalizing the KEV Catalog

The first step is to adopt CISA's KEV catalog as your organization's authoritative source for prioritizing vulnerabilities. This is a policy decision that means the KEV list supersedes other, less mature prioritization methods.

2. Remediating Vulnerabilities Within the Given Timelines

BOD 22-01 mandates that organizations fix each applicable KEV vulnerability by its assigned due date. Remediation has two valid options: either apply the vendor's patch or, if a patch is not possible, remove the vulnerable product from the network entirely.

3. Reporting on Status and Completion

Finally, BOD 22-01 requires organizations to report on their progress. For a private company, this means providing ongoing status updates and completion reports to internal leadership (such as a CISO, vCISO, CIO, and business-line managers). Regular reporting establishes a clear line of accountability and gives executives full visibility into the program's effectiveness.

Why Private Sector Companies Need to Adopt BOD 22-01

Beyond the federal government, adopting the principles of BOD 22-01 is a critical business strategy for private sector companies. It provides a clear, defensible model for managing real-world risk, which has direct and positive impacts on contracts, compliance, and resource planning. Here are four key reasons why your organization should align with it:

Supply Chain and Contractual Requirements

BOD 22-01 plays a key role in supply chain risk management (C-SCRM), helping organizations protect Controlled Unclassified Information (CUI) and strengthen their SPRS scores, both critical for defense contractors aiming to win DoD contracts. Frameworks like DFARS and CMMC demand a robust vulnerability management program, and BOD 22-01 provides the clear, auditable standard that prime contractors and federal agencies look for. 

Demonstrating Due Care

Aligning with the KEV catalog is a powerful way to demonstrate due care to regulators, cyber insurance providers, and partners. In the event of an audit or incident, you can provide clear evidence that your organization was proactively managing known, active threats rather than just reacting to theoretical risks.

Effective Resource Allocation

The KEV-first BOD 22-01 framework provides a clear, data-driven justification for prioritizing specific patches. It’s invaluable for CISOs and IT leaders who need to allocate limited budgets and staff, and ends the debate over "what to patch next" by focusing your team on the highest-impact tasks.

Measurable Risk Reduction

The KEV framework provides a more efficient path to risk reduction. It directs your team to prioritize resources on proven attack vectors. This focus neutralizes active threats faster, providing a measurable and demonstrable improvement to your security posture.

How to Prepare for BOD 22-01: A Step-by-Step Guide

Aligning with BOD 22-01 is a practical way to build a mature, data-driven vulnerability management program. Follow this six-step guide to implement it effectively:

1. Establish a Comprehensive Asset Inventory

The first step is the process of discovering and cataloging every device, piece of software, and cloud asset on your network. The core principle is simple: you cannot protect an asset or patch a vulnerability on a device you don't know exists. 

Without a continuous, automated inventory, modern IT environments with dynamic cloud instances and remote devices create inevitable blind spots. This inventory is the essential mechanism that translates the global KEV catalog into an actionable, internal remediation list.

How to do it:

• Deploy a combination of network scanning, agent-based systems, and cloud asset discovery tools to ensure 100% coverage.
• Consolidate all asset data into a central Configuration Management Database (CMDB) or a dedicated asset management platform to serve as a single source of truth.
• Establish clear ownership of every asset to create accountability for patching, updates, or decommissioning.
• Automate the discovery process to run continuously to capture temporary or new assets as they come online.

2. Integrate the KEV Catalog into Your Vulnerability Scanning

Once you know your assets, the next step is to integrate BOD 22-01’s KEV catalog directly into your vulnerability management platform. This is the critical link that connects CISA's real-world threat data to your specific environment. 

The goal is to automatically cross-reference the KEV list against your scan results, which should instantly flag any KEVs present on your assets. A manual, spreadsheet-based approach to check the KEV list against your scans is error prone and can’t keep pace with new threats. Automation is the only way to ensure that high-priority, active threats are flagged for your team the moment they are discovered.

How to do it:

• Check if your current vulnerability scanning tool has a built-in integration for the CISA KEV catalog; most major platforms now do.
• If an automated feed isn't available, utilize the JSON or CSV feeds provided by CISA to build a custom script or workflow.
• Configure your platform to use this feed to automatically tag or elevate the priority of any discovered vulnerability that matches a KEV entry.
• Run a test scan and verification to ensure the integration is working correctly and that KEVs are being flagged with the highest priority.

3. Update Your Internal Prioritization Policies

Integrating the KEV catalog gives your team the data, but your formal policies must give them the authority to act. Your vulnerability management policy should be rewritten to officially designate any KEV vulnerability as the organization's top remediation priority, superseding all other metrics. 

This updated policy is essential for providing the top-down BOD 22-01 mandate your security and IT teams need to act immediately. It also serves another key function: it ends the internal debates about CVSS scores versus real-world risk.

How to do it:

• Modify your official policy documents to create a "KEV-First" rule.
• Define a specific, aggressive Service Level Agreement (SLA) for remediating KEVs that is significantly shorter than for other vulnerabilities.
• Ensure this new policy is clearly communicated to all stakeholders, especially IT operations and asset owners who will be responsible for executing the remediation.
• Incorporate this policy into your compliance and audit documentation to demonstrate a mature, threat-based approach.

4. Operationalize a Rapid Remediation Process

A "KEV-First" policy is only effective when supported by a dedicated, rapid remediation process.  The next step is to operationalize it by creating and testing a streamlined workflow for patching or mitigating KEV vulnerabilities the moment they are identified.

The short deadlines mandated by BOD 22-01 (often 14 or 21 days) leave no room for improvisation, making a well-rehearsed process essential. This defined workflow acts as the practical bridge between the security team's discovery and the IT team's action which ensures clear accountability.

How to do it:

• Document the end-to-end process, clearly defining who is responsible for testing patches, deploying them to production, and verifying that the fix is successful.
• Use patch management automation and software deployment tools wherever possible to accelerate the rollout of critical updates.
• Conduct regular drills or tabletop exercises for KEV remediation to ensure the team can meet the aggressive SLAs defined in your new policy.
• Establish clear exception-handling procedures for assets that cannot be patched immediately (e.g., legacy systems) and define alternative mitigations, such as network isolation.

5. Report on KEV Metrics to Leadership

The fifth step is developing a simple reporting mechanism or dashboard view to track your organization's performance against the KEV catalog. Reporting provides accountability for the security and IT teams, but more importantly, it demonstrates the value of your BOD 22-01 security program to leadership. It allows you to show risk reduction in clear business terms, justify resource allocation, and build confidence with executives and the board.

How to do it:

• Track key, straightforward metrics: "Number of open KEVs," "Mean Time to Remediate (MTTR) for KEVs," and "Percentage of assets with one or more KEVs."
• Integrate these metrics into your existing CISO dashboard or leadership reports.
• Present these findings in an easy-to-understand format (such as trend lines or scorecards) during monthly or quarterly business reviews.
• Use the data to highlight successes ("We reduced our critical KEV exposure by 90% this quarter") and identify problem areas ("We are missing our SLA for legacy systems").

6. Partner with Vistrada for Expert Compliance

Executing the first five steps consistently can be a significant operational challenge. Successful alignment with BOD 22-01 requires a specific combination of dedicated personnel, specialized tools, and deep compliance expertise, which are resources that many mid-market companies don’t have on hand. 

Engaging an expert partner like Vistrada provides a clear path forward by ensuring the entire process is managed effectively. This approach gives leadership the assurance of compliance and frees internal teams to focus on their core business.

Get a Strategic Approach to Vulnerability Management

Aligning your cybersecurity program with BOD 22-01 moves your organization from a reactive, volume-based patching model to a proactive, threat-based one. Focusing on the KEV catalog allows cybersecurity leadership to direct resources to the vulnerabilities that pose a proven, immediate threat, which dramatically reduces risk and demonstrates due care. But successfully implementing this framework requires sustained expertise, the right tools, and operational rigor. 

Vistrada’s vCISO services provide cybersecurity leadership, hands-on execution, and full lifecycle support to help your organization meet the requirements of BOD 22-01 and other compliance mandates. Unlike traditional vCISO models, Vistrada delivers a team-based approach combining CISO strategy, analyst execution, and IT partnership. We help mid-market companies implement CMMC, NIST 800-171, and C-SCRM controls efficiently and cost-effectively.

Contact Vistrada to learn how we can build a measurable, defensible vulnerability management program grounded in real-world threats.