Governance & Risk Management,
Zero Trust
New NSA Recommendations Call for Ongoing Access Reviews and Overhauls in Implementation

The National Security Agency (NSA) has updated its mandates for federal agencies regarding the implementation of zero trust architecture, stressing the need for continuous, behavior-based security measures. This guidance emerges from heightened concerns that cyberattacks against U.S. government entities are increasingly evading traditional security protocols.
On Friday, the NSA released comprehensive documents outlining phase one and phase two of its zero trust recommendations. These frameworks are designed to help agencies reach the Department of Defense’s “target-level zero trust maturity.” The new guidelines build on previous federal efforts and advocate for an operational model that is sustained through every aspect of user or system interaction.
These recommendations, as stated by the NSA, aim to transition organizations from the discovery phase to full implementation through carefully structured steps that prioritize modularity and customization. Brian Soby, co-founder of SaaS security firm AppOmni, comments on the shift from “authenticate, then trust” to a model reliant on ongoing assessments based on user behavior, privilege requests, and resource interaction.
One major emphasis of the new guidance is the imperative for continuous evaluation post-login, countering the long-held practice of treating authentication as a singular checkpoint. This approach addresses the growing trend of sophisticated attacks that exploit vulnerabilities after successful credential compromises. Soby notes that while checks on device posture and initial login are important, they may become ineffective if real-time anomalies within user sessions remain undetected.
Despite many agencies still depending on legacy methods like device posture validations, the NSA highlights the need for synchronized policy decisions and enforcement mechanisms across enterprise environments to align real-world access controls with stated zero trust strategies. The guidance advocates for behavioral analytics, moving away from simplistic metrics such as login locations or device types, focusing instead on establishing baselines for normal user activities and identifying anomalies that may indicate privilege abuse or unauthorized data access.
In its structured approach, the guidance encourages agencies to build their zero trust frameworks incrementally, integrating identity, device, application, data, network, and automation aspects into a holistic system. The NSA aims for flexibility, allowing agencies to customize their zero trust implementations in accordance with specific organizational goals and constraints.
Though primarily directed at national security systems and defense sectors, this guidance has been made publicly accessible, enabling civilian agencies and industry partners to adopt uniform expectations across the public space. As the cyber landscape evolves, the importance of robust, real-time security measures becomes increasingly critical in safeguarding sensitive information against emerging threats.