Key takeaways
- The DoD Zero Trust Strategy requires Department of War components to achieve the Target Level outcomes of every Zero Trust capability no later than the end of fiscal year 2027. That year began on October 1, 2026 and ends on September 30, 2027.
- In DoD’s Zero Trust capability execution roadmap, the data pillar has seven capabilities and 31 activities, and 17 of those activities are required at Target Level. They run from data analysis and tagging standards through file activity monitoring, encryption, data loss prevention, and attribute-based access control.
- Several Target activities name storage directly. Activity 4.2.3 calls for a Software Defined Storage policy, activities 4.4.3 and 4.4.4 require file activity monitoring of critical and then all regulated data with analytics fed to the SIEM, and activity 4.7.4 integrates storage and other data security tools with the enterprise identity provider.
- Storage built for Zero Trust can carry the monitoring, encryption, and attribute-based access work at the data itself. The data catalog, tagging standards, and document-level rights management stay enterprise programs that storage supports but does not replace.
Fiscal year 2027 began on October 1, and it is the deadline year. The DoD Zero Trust Strategy, issued in 2022, requires Department of War (DoW, formerly DoD) components to achieve the Target Level outcomes of every Zero Trust capability no later than the end of FY2027, which falls on September 30, 2027. The strategy defines Target Level as the minimum set of outcomes and activities needed to protect the department’s data, applications, assets, and services against currently known threats.
In many programs, early progress came in identity and networking, where products were mature and results were easy to show. The data pillar is where a great deal of the remaining work sits, and it is the pillar in which storage decisions matter most. This guide walks through what the pillar requires at Target Level, capability by capability, and separates the activities the storage layer can carry from the ones it can only support.
What the data pillar requires at Target Level
DoD’s capability execution roadmap breaks the Zero Trust model into 45 capabilities and 152 activities, 91 of them at Target Level. The data pillar accounts for seven of those capabilities and 31 of the activities. Seventeen are Target Level, which puts them inside the FY2027 deadline, and the other 14 are Advanced. The table lists each capability’s Target activities next to what RackTop BrickStor SP contributes at the storage layer, including where an enterprise program has to do the rest.
| Capability | Target Level activities | What BrickStor SP contributes |
|---|---|---|
| 4.1 Data catalog risk alignment | 4.1.1 Data analysis | Labels and a per-operation audit show where tagged data lives and who touches it. The catalog itself is an enterprise process. |
| 4.2 Enterprise data governance | 4.2.1 Define data tagging standards; 4.2.2 Interoperability standards; 4.2.3 Develop Software Defined Storage (SDS) policy | BrickStor SP is software-defined NAS, so it belongs in the 4.2.3 SDS assessment. Tagging and interoperability standards are set by the enterprise. |
| 4.3 Data labeling and tagging | 4.3.1 Implement data tagging and classification tools; 4.3.2 Manual data tagging Pt1 | Datasets and files carry classification and program attributes at the storage layer, including dissemination markings, so tags become enforceable policy inputs. Deciding what a document is stays with tagging tools and data owners. |
| 4.4 Data monitoring and sensing | 4.4.1 DLP and 4.4.2 DRM enforcement point logging and analysis; 4.4.3 and 4.4.4 File activity monitoring Pt1 and Pt2 | Active Defense evaluates every file operation inline with identity, source IP, path, operation type, and timing, and integrates with SIEM and SOAR. This is file activity monitoring on the storage that holds the data. |
| 4.5 Data encryption and rights management | 4.5.1 and 4.5.2 Implement DRM and protection tools; 4.5.3 DRM enforcement via data tags and analytics Pt1 | Data at rest is encrypted per dataset with a FIPS 140-3 Level 1 validated module (version 23.8 and later), with integrated key management, automated key rotation, and HSM and KMIP support. Rights management that travels with a document is a separate tool. |
| 4.6 Data loss prevention | 4.6.1 Implement enforcement points; 4.6.2 DLP enforcement via data tags and analytics Pt1 | Active Defense stops bulk reads, systematic copying, and abnormal transfer patterns at the repository in under a second. It complements content-inspection DLP and does not replace it. |
| 4.7 Data access control | 4.7.1 Integrate DAAS access with SDS policy Pt1; 4.7.4 Integrate solutions and policy with enterprise IdP Pt1 | Attribute-based access control decides every SMB, NFS, S3, and Web Drive operation, using attributes from Active Directory and LDAP and decisions from policy engines such as Sentris. |
Three activities that name storage directly
Activity 4.2.3 asks the enterprise and components to determine whether software-defined storage is in use, develop policy and standards for it, and evaluate current storage strategy and technology for SDS. The enterprise also defines minimum attribution requirements for SDS to support Zero Trust. That assessment is the natural moment to ask whether the NAS platforms holding CUI and other regulated files can carry attributes and enforce policy at all. BrickStor SP is software-defined NAS that enforces attribute-based policy, including data labels, on every SMB, NFS, S3, and Web Drive operation.
Activities 4.4.3 and 4.4.4 require file activity monitoring, first for the most critical data classifications and then for all regulatory protected data such as CUI, PII, and PHI, with analytics fed into the SIEM and extended to tools such as DLP and user and entity behavior analytics. Active Defense does this inside the storage system. It inspects each file operation with the identity, source address, path, operation type, and timing attached, compares it against behavioral baselines for each user, host, and dataset, and records every operation in an immutable audit that includes the user’s attributes, the resource, the action, the decision, and the policy rule that applied. Because the monitoring happens where the files are served, coverage does not depend on agents on every endpoint or on a log feed the storage chooses to export.
Activity 4.7.4 integrates access-control and data-location attributes, and the DLP, DRM, and storage tools that use them, with the enterprise identity provider through interfaces such as APIs, LDAP, and SAML. BrickStor SP consumes attributes from Active Directory, LDAP, and other sources and applies attribute-based decisions from engines such as Sentris to each operation. That per-operation enforcement on software-defined storage is also what the Advanced activities 4.7.3 and 4.7.5 describe, so the platform that meets the Target integration supports the Advanced outcomes that follow.
Where storage supports the program without replacing it
Several Target activities belong to the enterprise. A data catalog aligned to risk (4.1.1), tagging and interoperability standards (4.2.1 and 4.2.2), and the classification tools that decide what a document is (4.3.1) are programs and tools that storage feeds rather than replaces. The same goes for document-level rights management that travels with a file after it leaves the repository, and for content-inspection DLP on endpoints and email.
What the storage layer adds is enforcement where the data actually lives. Labels on the data make tagging standards enforceable, per-operation audit gives the catalog and the SIEM ground truth about access, and behavioral detection on reads catches the bulk collection that DLP rules can miss. An assessor will still look for the enterprise programs, and storage-layer controls are what make those programs hold on the file shares where most unstructured data sits.
A year to go: where to start
With less than a year left, sequencing matters as much as coverage. The fastest gains usually come from finding where regulated files actually live, which is often on file shares and NAS platforms that predate the program, and deciding in the 4.2.3 assessment which of those platforms can carry attributes and enforce policy. File activity monitoring for the most critical data, feeding the SIEM, addresses 4.4.3 and builds the baseline that 4.4.4 extends to all regulated data. Validated encryption with managed keys addresses the at-rest protection in 4.5.3, and integrating storage with the enterprise identity provider addresses 4.7.4.
Building these controls into the storage platform also helps with accreditation, because logging, attribute-based access control, validated encryption, and immutable audit are present by design instead of assembled from separate tools. RackTop’s federal engineers can walk a component or integrator through how BrickStor SP maps to its own Target Level plan, and put the platform in its environment to test it.
Frequently asked questions
- No later than the end of fiscal year 2027, which is September 30, 2027. The DoD Zero Trust Strategy requires Department of War components to achieve the Target Level outcomes of every Zero Trust capability by then. Target Level covers 91 of the 152 activities in DoD’s Zero Trust capability execution roadmap.
- The data pillar has seven capabilities and 31 activities. Seventeen are Target Level and due by the end of FY2027, and 14 are Advanced. The capabilities are data catalog risk alignment, enterprise data governance, data labeling and tagging, data monitoring and sensing, data encryption and rights management, data loss prevention, and data access control.
- Activity 4.4.3 is a Target Level activity in the data pillar. Components use file monitoring tools to monitor the most critical data classification levels in applications, services, and repositories, and feed the analytics into the SIEM. Activity 4.4.4 extends the monitoring to all regulatory protected data, such as CUI, PII, and PHI. RackTop BrickStor SP performs file activity monitoring inside the storage system and integrates with SIEM and SOAR.
- Activity 4.2.3, Develop Software Defined Storage (SDS) Policy, is a Target Level activity. The enterprise and components determine whether software-defined storage is in use, develop policy and standards for it, and evaluate current storage technology for SDS, while the enterprise defines minimum attribution requirements for SDS to support Zero Trust. Later activities integrate SDS with attribute-based access policy and the enterprise identity provider.
- No. Storage can carry the file activity monitoring, encryption at rest, and attribute-based access control activities at the data itself, but the data catalog, tagging standards, classification tools, document-level rights management, and endpoint DLP remain enterprise programs. Storage-layer labels, audit, and detection make those programs enforceable on file shares and NAS.Zero Trust reaches the data pillar: CISA vs DoD compared
Sources
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