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.
Trello
by Atlassian
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Project Management
Overview
Trello is a commercial kanban-style project management tool owned by Atlassian. Unlike Jira Cloud for Government, the standard Trello product is not FedRAMP authorized for CUI workloads.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Using Trello in a Defense Contractor Environment
Trello poses significant compliance risks for defense contractors handling CUI, as it lacks FedRAMP authorization and cannot meet NIST 800-171 requirements. Defense contractors commonly use Trello for project tracking involving technical specifications, contract deliverables, milestone schedules, and team communications - all of which frequently contain CUI such as technical data (ITAR-controlled), procurement sensitive information, and operational schedules. Within a CMMC Level 2 authorization boundary, Trello would be classified as a CUI system requiring full 110 control implementation, but its cloud-hosted architecture on non-FedRAMP infrastructure creates immediate boundary violations. No compensating controls can adequately address the fundamental issue of CUI residing on non-authorized cloud infrastructure. DCMA and DIBCAC assessors consistently flag unauthorized cloud services like standard Trello as major findings during CMMC assessments, particularly focusing on AC-17 (Remote Access), SC-7 (Boundary Protection), and SC-8 (Transmission Confidentiality). Recent DCMA compliance reviews have specifically identified Atlassian's standard products as common non-compliance areas, with assessors requiring immediate remediation or CUI removal. The tool's ease of use often leads to inadvertent CUI proliferation across boards and cards, creating widespread compliance exposure that extends beyond the initial implementation scope.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Trello 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 migrate away from standard Trello to maintain CMMC compliance, with migration timelines typically requiring 8-12 weeks for complete remediation. Phase 1 (weeks 1-2): Conduct comprehensive CUI inventory across all Trello boards, cards, and attachments, documenting data classifications and implementing immediate access restrictions. Phase 2 (weeks 3-4): Export all project data while ensuring CUI handling protocols during data transfer, requiring encrypted storage of exported files on approved systems. Phase 3 (weeks 5-8): Implement replacement solution such as Jira Cloud for Government (FedRAMP authorized) or Microsoft Project Online (GCC High), including user account provisioning and permission structure recreation. Phase 4 (weeks 9-12): Complete user training on new platform, validate CUI migration, and update all compliance documentation. Critical considerations include maintaining audit trails during migration and ensuring no CUI remains in Trello after project completion. Recommended alternatives include Jira Cloud Government ($7-15/user/month), Microsoft Project Plan 3 GCC High ($30/user/month), or Smartsheet Gov ($25/user/month). Total migration costs typically range from $15,000-50,000 for organizations with 50-200 users, including licensing, professional services, and compliance documentation updates.
Migration Checklist
- 1ISSO must immediately inventory all Trello instances and boards containing potential CUI, documenting findings in a POA&M entry referencing NIST 800-171 3.1.1 violation.
- 2Contracts officer must review all DoD contracts to identify DFARS 252.204-7012 applicability and determine CUI exposure scope across Trello usage.
- 3Sysadmin must implement immediate access restrictions to prevent new CUI uploads to existing Trello boards until migration completion.
- 4ISSO must update the authorization boundary diagram to remove Trello from the CUI environment and document the compliance gap.
- 5Legal team must coordinate with Atlassian to ensure proper data deletion procedures align with DFARS 252.204-7012 requirements.
- 6ISSO must procure FedRAMP authorized alternative (Jira Cloud Government or equivalent) and validate its authorization status through GSA marketplace.
- 7Sysadmin must execute controlled CUI data export from Trello using encrypted transfer methods and approved temporary storage.
- 8ISSO must configure new platform with appropriate NIST 800-171 controls including multi-factor authentication, audit logging, and access controls.
- 9Training coordinator must conduct user education sessions on new platform and CUI handling procedures within the replacement system.
- 10ISSO must update SSP sections 2.3 (system inventory) and 10.2 (information system architecture) to reflect Trello removal and new platform integration.
Compliance Cross-References
Trello's non-compliance creates cascading violations across multiple NIST 800-171 control families, particularly Access Control (AC) due to inadequate user authentication and authorization mechanisms for CUI access. System and Communications Protection (SC) violations occur through unencrypted data transmission and storage outside FedRAMP boundaries, while Audit and Accountability (AU) failures result from insufficient logging capabilities for CUI access events. The tool triggers DFARS 252.204-7012 clause violations for inadequate safeguarding of CUI and 252.204-7021 violations for cybersecurity requirements non-compliance. Within CMMC Level 2 assessment domains, Trello creates findings in Access Control (AC.L2), System and Information Integrity (SI.L2), and Configuration Management (CM.L2) practices. The compliance chain flows from FedRAMP authorization gaps to NIST 800-171 control implementation failures, ultimately resulting in CMMC assessment findings that can prevent contract award or continuation.
NIST 800-171 Violations
Using Trello 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 Trello FedRAMP authorized?
No. The standard Trello product is not FedRAMP authorized. Only Atlassian's dedicated Government Cloud products hold authorization.
Can I use Trello with CUI?
No. Trello is not authorized for CUI. Use Jira Cloud for Government from the same vendor for a compliant alternative.
What is a compliant alternative to Trello?
Jira Cloud for Government (FedRAMP Moderate) from Atlassian and Smartsheet Government (FedRAMP Moderate) are authorized alternatives.
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