Background
The release of OMB Memorandum M-26-14 on May 22, 2026, marks a profound shift from a compliance-heavy logging mandate to an agile, risk-based operational capability, formally rescinding the rigid frameworks established under M-21-31. While M-21-31 was a critical post-SolarWinds reactive measure designed to raise federal event logging (EL) baselines, its prescriptive demands for retaining vast quantities of data without clear utility proved to be cost-prohibitive and operationally impractical for most agencies.
M-26-14 corrects these inefficiencies by streamlining requirements into two core, outcome-driven operational objectives: Continuous Event Monitoring (CEM) for real-time threat detection via Security Operations Centers (SOCs) and Threat Hunting, Investigation, Response, and Forensics (THIRF). By introducing a flexible five-level maturity model and easing data retention to a standard of six months searchable and twelve months retrievable, the new directive empowers security leaders to scale logging architectures around mission risk rather than exhaustive compliance checklists.
Overall Project Objective and Mission
To operationalize this newly released directive ahead of the Cybersecurity and Infrastructure Security Agency's (CISA) upcoming 90-day deadline to publish the Logging Reference Architecture (LRA), we propose an 8-Week Collaborative Review Sprint. This high-impact project will assemble a cohort of public and private sector leaders to dissect M-26-14's revised performance benchmarks across critical elements like Inventory Visibility, Collection Coverage, and Log Management Planning.
Project Approach
Over the eight-week period, the working group will evaluate data ingestion pipelines, map architectural variations permitted under the new adaptive framework, and draft modular templates that agencies can immediately leverage to construct their mandatory 90-day Agency Logging Plans. Crucially, this ACT-IAC initiative will expand its analytical focus beyond the federal enterprise to explicitly address the downstream architectural needs of state and local government partners. Because state entities may inherit federal cybersecurity logging baselines through mechanisms like GovRAMP and federal grant requirements (such as the State and Local Cybersecurity Grant Program), or data sharing requirements (e.g. IRS Safeguards, CJI), the review sprint will evaluate the technical and financial hurdles states and local governments face when trying to align with federal cybersecurity policy. By synthesizing federal mission parameters with state-level resource constraints, the project's final deliverable will establish a unified, nation-wide framework capable of responding to automated, AI-driven adversaries impacting all levels of government.
Duration and Timeline
The project will begin as soon as possible following approval and is expected to run for a total of eight weeks from kickoff to delivery, consistent with ACT-IAC short-form project requirements. There are no known dependencies on other ongoing ACT-IAC or federal initiatives that would affect the project’s schedule or sequencing.
Outcomes and Deliverables
The project will produce a written report detailing an analysis of M-26-14's revised performance benchmarks across critical elements, evaluate data ingestion pipelines, map architectural variations permitted under the new adaptive framework, and draft modular templates that agencies can immediately leverage to construct their mandatory 90-day Agency Logging Plans.
In addition to the report and presentation, the project team will prepare a short executive briefing or summary deck to support communication and decision-making for the audience.
The project deliverables will be provided directly to the Federal CISO Council for review and consideration.
Membership
Project membership will include both government and industry participants under the ACT-IAC framework. Members should have experience or expertise relevant to logging, storage and the assorted memoranda applicable to those in a federal/state cyber program context.
Sign up to volunteer by July 1, 2026.
For questions, email [email protected]