Which elements are required for accreditation and authorization to operate (ATO) for CUI-storing systems?

• A. Regular encryption is sufficient without formal authorization.
• B. Systems storing CUI must have appropriate security authorization, ongoing risk management, and monitoring.
• C. Only annual audits are required.
• D. CUI storage requires no special authorization.

Answer: (B)

Security authorization to operate for systems storing CUI requires a formal authorization decision plus ongoing risk management and continuous monitoring. The authorization step is a formal acceptance by an approving official that the system’s security controls are in place and functioning adequately to protect CUI, given the system’s risk posture and mission needs. But that authorization isn’t a one-and-done event; it rests on ongoing processes that continuously assess and manage risk as the system changes. Continuous monitoring keeps the authorization current by regularly evaluating control effectiveness, detecting new vulnerabilities, and ensuring responses to threats remain appropriate.

This combination—formal authorization, ongoing risk management, and continuous monitoring—is essential to maintain protection for CUI over the system’s lifecycle. Relying on encryption alone won’t substitute for formal authorization and ongoing oversight, and expecting only annual audits misses the need for real-time risk assessment and control validation. There is also no basis for claiming that CUI storage requires no special authorization.