Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Collabora Online
by Collabora
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Office Suite
Overview
Collabora Online is an open-source, self-hosted office suite based on LibreOffice technology. While it can be deployed on-premises, it is not FedRAMP authorized as a cloud service.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Using Collabora Online in a Defense Contractor Environment
Collabora Online presents significant compliance challenges for defense contractors handling CUI. As a self-hosted office suite, it typically processes technical specifications, engineering drawings, financial data, and personnel information that constitute CUI under DFARS 252.204-7012. Within a CMMC Level 2 authorization boundary, Collabora Online would require dedicated CUI processing infrastructure with proper network segmentation, access controls, and audit logging. However, its lack of FedRAMP authorization creates immediate compliance gaps. Compensating controls would include air-gapped deployment, enhanced encryption at rest and in transit, comprehensive audit logging, and documented security assessments. DCMA/DIBCAC assessors consistently flag non-FedRAMP authorized cloud collaboration tools during CMMC assessments, viewing them as high-risk CUI processing systems. Recent DCMA compliance reviews have specifically cited office suites without proper authorization as contributing to NIST 800-171 violations, particularly in access control and system communications protection domains. The open-source nature of Collabora Online adds complexity to security assessments, as assessors must evaluate the organization's ability to maintain security patches and configurations without vendor support. Defense contractors using Collabora Online face significant POA&M entries and potential contract compliance issues unless migration to FedRAMP authorized alternatives occurs.
Deployment & Architecture
Deployment Model: Self-hosted (open-source)
Collabora Online lacks FedRAMP authorization. Using this tool for CUI processing violates DFARS 252.204-7012 requirements. Defense contractors must evaluate FedRAMP-authorized alternatives or implement and document compensating controls in their POA&M.
Migration Guidance
Defense contractors must immediately initiate migration from Collabora Online due to FedRAMP non-compliance. Migration timeline: 8-12 weeks across three phases. Phase 1 (weeks 1-3): Conduct CUI data inventory within Collabora Online instances, identify all document repositories, and establish data classification protocols. Export all CUI documents using LibreOffice-compatible formats while maintaining audit trails per NIST 800-171 3.3.1. Phase 2 (weeks 4-8): Deploy FedRAMP authorized alternative such as Microsoft 365 GCC High or Google Workspace for Government, configure security controls, and establish user provisioning workflows. Update System Security Plan to remove Collabora Online from authorization boundary and add replacement solution. Phase 3 (weeks 9-12): Conduct phased user migration with mandatory training on new platform security features, update all contract documentation referencing the office suite, and create POA&M closure documentation. User training must emphasize CUI marking requirements and data handling procedures in the new environment. Cost estimate: $75,000-$150,000 including FedRAMP authorized licensing ($40-60/user/month), migration consulting services, user training, and compliance documentation updates. Recommended alternatives: Microsoft 365 GCC High for comprehensive collaboration or Google Workspace for Government for cloud-native organizations. Document all migration activities in the Continuous Monitoring program to demonstrate due diligence to DCMA assessors.
Migration Checklist
- 1ISSO must immediately add Collabora Online to the POA&M as a high-risk finding referencing NIST 800-171 controls 3.1.1, 3.1.2, 3.13.1, and 3.13.8 violations.
- 2System administrator must conduct comprehensive audit of all Collabora Online instances to identify CUI processing locations and document current usage patterns.
- 3ISSO must update the System Security Plan to reflect Collabora Online's compliance status and initiate authorization boundary modification procedures.
- 4Contracts officer must review all active DoD contracts to identify specific CUI requirements and notification obligations under DFARS 252.204-7012.
- 5System administrator must implement immediate access restrictions to prevent new CUI uploads to Collabora Online pending migration completion.
- 6ISSO must evaluate and procure FedRAMP authorized office suite alternatives, prioritizing Microsoft 365 GCC High or Google Workspace for Government based on organizational needs.
- 7Legal counsel must assess potential contract compliance violations and develop notification strategy for contracting officers regarding the compliance gap.
- 8System administrator must execute secure data migration procedures ensuring CUI markings and access controls are preserved during transition to compliant platform.
- 9ISSO must conduct post-migration security assessment to validate proper CUI handling in the new environment and update all compliance documentation.
- 10ISSO must brief senior leadership on compliance restoration timeline and submit POA&M closure documentation to DCMA within 30 days of migration completion.
Compliance Cross-References
Collabora Online's non-compliant status directly impacts multiple NIST 800-171 control families, creating cascading compliance failures across the CUI environment. Access Control (AC) family violations occur through inadequate user authentication and authorization mechanisms in non-FedRAMP systems, specifically controls 3.1.1 and 3.1.2. System and Communications Protection (SC) family failures emerge from insufficient encryption and transmission security controls, violating 3.13.1 and 3.13.8 requirements. This triggers DFARS 252.204-7012 adequate security clause violations and 252.204-7021 cybersecurity maturity requirements. Within CMMC Level 2 assessment domains, Collabora Online creates findings in Access Control (AC.L2), System and Information Integrity (SI.L2), and System and Communications Protection (SC.L2) domains. The lack of FedRAMP authorization fundamentally violates the requirement that CUI processing systems demonstrate adequate security through recognized certification processes, creating a direct path to CMMC assessment failures and potential contract suspension under DFARS provisions.
NIST 800-171 Violations
Using Collabora Online for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Frequently Asked Questions
Is Collabora Online FedRAMP authorized?
No. Collabora Online does not hold FedRAMP authorization. Self-hosted deployments on compliant infrastructure may be evaluated on a case-by-case basis.
Can I use Collabora Online with CUI?
Collabora Online is not FedRAMP authorized. If self-hosted on FedRAMP High infrastructure, it may be acceptable with documented risk acceptance and security assessment.
What is a compliant alternative to Collabora Online?
Microsoft 365 GCC High and Google Docs Government provide FedRAMP authorized collaborative document editing for defense contractors.
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