The U.S. is a favorite target for threat actors. Often, those threat actors take advantage of unsupported devices residing on the edge of an organization’s network perimeter. Firewalls, VPNs, routers, IoT devices, and even personal devices like smart watches and cameras are all potential entry points, especially when they’ve reached the end of support (EOS). To mitigate these issues, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) issued a directive (CISA BOD 26-02) requires federal agencies to inventory all devices on the CISA EOS Edge Device List and report that inventory to CISA within 90 days of issuance, with longer-term requirements for decommissioning and lifecycle governance.
Binding Operational Directive 26-02 (BOD 26-02) is CISA drawing a hard line on EOS edge devices. Without regular patching or vendor support, existing vulnerabilities persist. Attackers know that those devices, when exposed externally, provide a perfect entry point and pivot point for lateral movement into federal networks.
BOD 26-02 sets deadlines for inventory, decommissioning, and ultimately, continuous discovery, so EOS devices don’t creep back in after the initial sweep is finished.
BOD 26-02 intends to minimize organizational risk and to shift how federal agencies approach edge device management. The shift?
Stop treating refresh like a “big bang”
Most agencies fail at edge device lifecycle management because the refresh gets delayed until the process becomes untenable and overwhelming. Those delays can stem from limited staffing, low tolerances for outages, or simply not maintaining the asset inventory. Regardless, budget is always a factor. By the time approved devices make it through procurement and into production, they’re already closer to end-of-life than anyone expected.
They always say the best way to eat an elephant is one bite at a time. Modernizing an IT environment is similar.
Few organizations can afford to do a wholesale replacement at once. The best strategy is to break the whole into manageable projects. By working incrementally, you can decrease risk, minimize outages, and enable more predictable funding.
It also helps the process if your organization can standardize edge stacks. Fewer design types and versions lead to less chaotic environments and easier update paths.
Finally, design your IT architecture for replacement. Again, less is more. Focus on modular architectures and clean change windows that enable repeatable cutovers.
BOD 26-02 is lighting a fire under federal agencies. As of its issuance in February 2026, it requires agencies to immediately update any devices that do not pose an impact on mission critical functionality. Within 3 months – May 2026 – agencies must inventory and report all edge devices listed on the CISA’s EOS list using the CISA-provided template.
Here are a few practical steps that you can take to manage edge devices across federal networks and build a lifecycle modernization strategy.
BOD 26-02 ultimately requires continuous discovery + inventory of EOS/soon-to-be-EOS edge devices. If you treat modernization like an operational discipline, not a compliance drill, you’ll have the tools to continuously track every edge device with:
It’s not always practical to update everything all at once. Instead, use a staggered approach.
The timeline for BOD 26-02 calls for significant progress at both 12 months and 18 months. At those milestones, agencies must decommission and report, first for listed devices, then for all EOS edge devices. Specifically:
That means acquisition plans should lock early with:
Every device needs a verified identity. With your new, comprehensive inventory, now is the time to revisit zero trust concepts like multi-factor authentication (MFA), asset identity, workload isolation, and encryption in transit.
In fact, refreshing edge devices is your chance to modernize:
With BOD 26-02, CISA is telling agencies: unsupported edge devices are an unacceptable risk, and this one is easily remedied with disciplined lifecycle management and steady refresh. The fastest way to win is to stop waiting for a massive tech refresh. Instead make refresh a repeatable, budgetable, annual operating rhythm.
Are you ready to get started with incremental modernization of your edge devices? GuidePoint Security can help. We work with government agencies of all sizes and at all levels of federal, state, and local government, providing tailored solutions and services so you can complete your mission with better cybersecurity decisions that minimize risk.
Timothy Amerson
Federal Chief Information Security Officer (CISO),
GuidePoint Security
Timothy Amerson is currently the Federal Chief Information Security Officer (CISO) at GuidePoint Security. While also serving as the the President of the Board of Directors for The KEY (Keep Elevating Yourself) Community Non-Profit. He brings more than 30+ years of distinguished service in federal cybersecurity leadership. Most recently, he served as the CISO and Associate Commissioner at the Social Security Administration (SSA), where he was recognized as a 2023, 2024 and 2025 Top 100 Information Security Professional; 2024 FedScoop Top 50 Federal Leader Nominee; 2025 CyberScoop Government Leaders, FedScoop Top 50 Federal Leader Nominee, and Finalist US Forces in Business Lifetime Achievement Award.
At SSA, Mr. Amerson was responsible for enterprise-wide cybersecurity operations including Cybersecurity Risk Management (CSRM), Zero Trust Architecture (ZTA), FISMA compliance metrics, 24x7 Security Operations Center (SOC), Continuous Diagnostics and Mitigation (CDM), Red and Blue Team operations, Vulnerability Management, Insider Threat programs, Cyber Supply Chain Risk Management (C-SCRM), and secure software practices. Under his leadership, SSA’s FISMA scores increased from 70% to 98%, elevating the agency to one of the top performers across all Federal Civilian agencies.
Prior to SSA, Mr. Amerson held multiple senior leadership roles at the Department of Veterans Affairs (VA), including Director of Infrastructure Cybersecurity Management, Cybersecurity Product Line Manager, and (Detailed) Director of the National Data Center Operations and Logistics program. He was named a 2021 FedScoop “Best Bosses in Federal IT” finalist for his transformational leadership. He began his Federal Civilian IT career on the help desk at the Texas National Guard Joint Force Headquarters and rose through the ranks to become Chief Technology Officer.
Mr. Amerson is a decorated Army veteran with 32 years of service, including combat and state-side deployments, and has served as Platoon Leader, Commander, and Operations Officer. Also served as Deputy of the Computer Emergency Response Team, Deputy of the Defense Cyberspace Operations Element, and established the first multi-state Cyber Protection Team (CPT). He participated in and led Red and Blue Team activities during major national cyber exercises, including Cyber Storm (DHS), Cyber Shield (USCYBERCOM), and Cyber Guard (NGB), in partnership with the NSA, FBI, FEMA, and ODNI. He has received numerous commendations, including the Legion of Merit, Bronze Star Medal, four Meritorious Service Medals, and recognition from several professional associations, including the Silver Order of Thor (Cyber), the Silver Order of Mercury (Signal), and the Bronze Order of Saint George (Cavalry).
He holds a Master of Science in Computer Science a Specialization in Cybersecurity (Summa Cum Laude) and a Bachelor of Science in Computer Information Systems, is a graduate of the Army Cyber Center of Excellence and the Command & General Staff College, and maintains over 30 certifications, including Certified Information System Security Professional (CISSP), Project Management Professional (PMP), Certified Ethical Hacker (CEH and Hall of Fame), Certified Chief Information Security Officer (aC|CISO), Certified Competency in Zero Trust (CCZT), International Society of Automation (ISA)/International Electrotechnical Commission (IEC) 62443 Cybersecurity Expert, and Microsoft Certified Educator (MCE).
In his personal time, Mr. Amerson is passionate about cybersecurity, education, and outreach. He served as a conference coordinator for the Texas Cyber Summit and DEF CON, and mentored students on cybersecurity teams at both the high school and collegiate levels, resulting in numerous national awards, grants, and scholarships.