I cannot imagine the cost and level of effort for this CISA directive related to the Solarwind incursion. I'm sure that compliance will come with high cost and effort , given the breadth of the Solarwids incursion and the forensic requirements.

I have a number of friends working in government that will be spending their weekends trying to meet these requirements:

Summary of Required Actions

This supplemental guidance v3 requires (1) agencies that ran affected versions conduct forensic analysis, (2) agencies that accept the risk of running SolarWinds Orion comply with certain hardening requirements, and (3) reporting by agency from department-level Chief Information Officers (CIOs) by Tuesday, January 19, and Monday, January 25, 2021.

Here are the forensic requirements specified in the directive:

Appendix A – Required Forensics Investigation Actions

Agencies that ran affected versions of SolarWinds Orion platform (Category 2 and Category 3) at any time prior to the issuance of ED 21-01 must conduct system memory, host storage, network, and cloud forensic analysis and hunt for indicators of compromise (IOCs) or other evidence of threat actor activity, such as secondary actions on objectives (AOO)¹¹ as outlined in AA20-352A, such as user impersonation, privilege escalation, and data exfiltration.

1. Agencies running affected versions that have no capability to conduct forensic analysis (system memory, host storage, network, and cloud) shall, at minimum, hunt for IOCs or other evidence of threat actor activity published in ED 21-01, Activity Alert AA20-352A, and future associated guidance. Agencies that, through hunting and/or forensic analysis, find these IOCs or evidence of threat actor activity, such as secondary AOO, shall assume breach and must report it as an incident to CISA through https://us-cert.cisa.gov/report. If a reporting agency already submitted incident information to CISA, please send updates to CISA as you discover new evidence.

2. Agencies running affected versions that have no capability to conduct forensic analysis and no capability to hunt for IOCs shall assume breach, report the incident to CISA through https://us-cert.cisa.gov/report, and contact Central@cisa.dhs.gov to coordinate finding a qualified service provider capable of conducting forensics. Agencies whose forensics service provider’s analysis finds IOCs or evidence of threat actor activity, such as secondary AOO, shall update the incident report to CISA through https://us-cert.cisa.gov/report.