What Is the Difference between ATO and Continuous ATO?

TL;DR: ATO vs. Continuous ATO (cATO)

A traditional Authorization to Operate (ATO) is a time-bound risk acceptance decision based on a point-in-time security assessment—typically valid for up to three years. While effective for static systems, it's often too slow for modern software delivery and can delay mission-critical capabilities.

Continuous ATO (cATO) is a DoD implementation of the NIST RMF’s ongoing authorization model, designed to support continuous delivery. After receiving an initial ATO, systems must demonstrate maturity in continuous monitoring, active cyber defense, and DevSecOps practices to maintain real-time risk visibility and operational security.

The key difference: Traditional ATOs require periodic reauthorization, while cATO enables continuous risk-informed operation as long as conditions are met—supporting faster updates, improved transparency, and reduced operational overhead.

Why Use Continuous ATO?

According to Forbes, cybersecurity attacks increased by 72% between 2021 and 2023. In the business world, these attacks cause significant financial losses that average $4.45 million. For government, this can result in disruption on the battlefield or in the delivery of critical services.

To ensure a system can protect sensitive information and perform its intended functions without exposing the network to an unacceptable level of risk, government information systems require an Authorization to Operate (ATO). Unfortunately, Traditional ATOs can be time-consuming and often lead to delays in deploying critical systems due to their static, point-in-time assessments. Our Warfighters and citizens pay the price for these delays.

Software development across the federal government requires a more rapid, dynamic, and robust approach— continuous Authority to Operate (cATO). Done correctly, cATO leverages an ongoing authorization tailored for the swift and continuous delivery of higher-quality, secure software.

Note: ATOs are often colloquially referred to as an “Authority to Operate.” The technical term is “Authorization to Operate.” This guide will occasionally use the colloquial term in addition to the technical phrase.

What Does ATO Stand For?

ATO stands for Authorization to Operate; it’s a formal declaration that a system meets the necessary government security and privacy standards for deployment as the Federal Information Security Modernization Act (FISMA) requires. It represents a formal commitment to managing security and privacy risks for federal government, including the Department of Defense (DOD) ATO process to implement changes in mission-critical information systems. Unfortunately, the traditional ATO does not support real-time modifications to address changes to technology or emerging threats.

What Is a continuous ATO?

Continuous Authority to Operate (cATO) is the uncodified term used to describe a specific subset of ongoing authorization tailored for continuous software delivery. cATO is designed to integrate continuous monitoring and Agile methodologies, maintaining security and compliance in real time as systems and software are developed and updated. cATO emphasizes continuous assessment and improvement to identify, mitigate, and manage risk over time.

What is continuous monitoring according to NIST? The National Institute of Standards and Technology (NIST) Risk Management Framework (RMF) includes continuous monitoring as an essential step to risk management. NIST 800-137 defines information security continuous monitoring as an organization’s “ongoing awareness of their information security posture, vulnerabilities, and threats,” and addresses the assessment and analysis of security control effectiveness.

While there are no official guidelines set by NIST for continuous ATO, DOD outlines three distinct criteria for successfully achieving cATO: continuous monitoring, active cyber defense, and adoption/implementation of DevSecOps.

What Is the Difference between ATO and continuous ATO?

Traditional ATO and Continuous ATO (cATO) both serve to authorize systems to operate at an acceptable level of risk, but they take fundamentally different approaches to risk management. Below is a side-by-side comparison of how they differ in practice.

ATO cATO
Assessment style Captures a static security snapshot. Assesses on an ongoing, real-time basis.
Authorization timeline Time-bound; typically valid for up to three years. Continuous; persists as long as risk is managed and conditions are met.
Renewal approach Requires full reauthorization, often restarting documentation and review cycles. Uses incremental updates and continuous risk acceptance to avoid full resets.
Delivery speed impact Slows deployment due to lengthy approval cycles. Enables rapid delivery by aligning with continuous delivery workflows.
Risk management Risk is assessed periodically, leaving windows where threats may go undetected. Risk is continuously identified, mitigated, and reassessed.
Operational burden Creates repeated documentation and review overhead. Distributes compliance across the SDLC and automates evidence collection.
Security posture visibility Limited visibility between reviews. Real-time visibility into system security posture.
Agility Change often triggers major delays. Supports frequent, secure changes without reauthorization delays.

What Is a continuous ATO Example?

Ongoing authorization allows organizations to update software in near real-time, as changing technology or emerging threats require.

For example, the Department of Defense may need to rework itstheir fuel management system for a specific location. This system could track fuel supply chains and demands while having functionality to initiate fuel orders and scheduling.

This example includes multiple moving parts: tracking, analysis, and ordering. Under a traditional ATO, major updates would require the static, point-in-time assessment to restart. With cATO, the shift from periodic reauthorization to ongoing assessment and authorization provides a flexible framework for frequent updates and modifications while ensuring systems remain secure and functional over time. cATO benefits include an improved security posture with lower risk; increased transparency and trust; and reduced cost with increased delivery of value to the user.

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We create environments where changes are implemented swiftly and securely, proving that with the right team and mindset, continuous delivery can reshape the future—one where fewer bad things happen because of bad software.

Embracing cATO isn’t about checking boxes; it’s about revolutionizing the speed and safety with which you can deliver software. If you’re ready to transform the way your organization approaches software development, contact us to learn more about how we enable large enterprises to continuously deliver valuable software that users love.

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