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.
FreshBooks
by Freshworks
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Accounting
Overview
FreshBooks is a commercial invoicing and accounting platform for small businesses and freelancers. It is not FedRAMP authorized and does not support government contract accounting requirements.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
FreshBooks has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO must immediately conduct a data inventory to identify all CUI financial records currently stored in FreshBooks and document findings in the POA&M.
- 2Contracts officer must review all active contracts to determine which financial data constitutes CUI under DFARS 252.204-7012 requirements.
- 3ISSO must update the System Security Plan to reflect FreshBooks as an unauthorized system outside the CUI authorization boundary.
- 4System administrator must implement network-level blocking to prevent new CUI data from being uploaded to FreshBooks systems.
- 5ISSO must evaluate FedRAMP-authorized accounting alternatives and document selection criteria in compliance assessment reports.
- 6Data migration team must export all financial data from FreshBooks using encrypted channels and verify complete CUI data removal from vendor systems.
- 7System administrator must configure the replacement accounting system with NIST 800-171 security controls including multi-factor authentication and audit logging.
- 8ISSO must update the authorization boundary diagram to remove FreshBooks and include the new compliant accounting system.
- 9Training coordinator must provide NIST 800-171 awareness training to all users of the new accounting system within 30 days of implementation.
- 10ISSO must validate migration completion through penetration testing and update the continuous monitoring program to include the new accounting system.
NIST 800-171 Violations
Using FreshBooks for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Related Compliance Assessments
Frequently Asked Questions
Is FreshBooks FedRAMP authorized?
No. FreshBooks does not hold FedRAMP authorization and is designed for small business invoicing, not government contracting.
Can I use FreshBooks for defense contract accounting?
No. FreshBooks lacks FedRAMP authorization and DCAA-compliant cost accounting features required by defense contractors.
What is a compliant alternative to FreshBooks?
Deltek Costpoint (FedRAMP Moderate) is the standard for government contractor accounting. SAP Government Cloud (FedRAMP High) serves enterprise needs.
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