Publicly Accessible Content

“Publicly accessible content” sounds like a web-team concern. In FedRAMP and NIST terms, it is an access control problem with real audit teeth: any path that exposes information to the public has to be governed the way you govern privileged access. AC-22 expects you to control who can publish, validate what they publish before it becomes public, and keep checking what’s already out there for nonpublic information, with a defined cadence. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest way to operationalize this is to treat “public posting” as a controlled change to an internet-exposed system. That gives you a clean mapping to: role-based authorization, documented approvals, routine reviews, and incident-style removal when something sensitive is discovered.

This page gives requirement-level implementation guidance you can hand to owners (Marketing, Product, Support, IT, Security) and assessors (3PAO) without translating it three times. It also focuses on evidence: what to keep so you can pass initial authorization and continuous monitoring expectations commonly driven by FedRAMP documentation patterns. ²

Regulatory text

Requirement (AC-22): “Designate individuals authorized to make information publicly accessible; review the proposed content of information prior to posting; review content on the publicly accessible system for nonpublic information at an organization-defined frequency; and remove nonpublic information if discovered.” ¹

What the operator must do

AC-22 is four obligations that must all be true:

1. Designate authorized publishers. You must explicitly name roles (or individuals) who are permitted to post content that becomes public. “Anyone with a login” fails this intent. ¹

2. Pre-publication review. Before a post goes live, content must be reviewed. This is a procedural gate to prevent nonpublic information from being exposed. ¹

3. Periodic review of what’s already public. You must review content already on publicly accessible systems for nonpublic information, at a frequency you define. The key audit point is that the frequency is defined and evidenced. ¹

4. Removal and response. If nonpublic information is discovered, you remove it. In practice, you also document the removal, scope, and follow-up actions so the issue doesn’t repeat. ¹

Plain-English interpretation (what AC-22 is really testing)

Assessors are testing whether your organization can prevent accidental data disclosure through public channels and whether you can prove you are watching those channels over time.

“Publicly accessible” includes more than the marketing website. A few common examples inside FedRAMP boundaries:

• Public documentation sites and knowledge bases
• Public code repositories and gists (including org-managed repos)
• Public-facing ticket portals and community forums
• Public status pages and incident write-ups
• Public object storage paths (misconfigured buckets or containers)
• Public API documentation explorers and sample requests/responses

“Nonpublic information” is whatever your program defines as not intended for public release (for example: customer data, federal information, internal system details, credentials, internal IPs, private URLs, security architecture diagrams, or internal-only procedures). AC-22 does not define your classification scheme; it expects you to have one and apply it consistently through these workflows. ³

Who it applies to

Entity scope

• Cloud Service Providers (CSPs) operating a FedRAMP-authorized cloud service offering: you must implement AC-22 within the authorization boundary for systems and processes that publish or expose content. ¹
• Federal Agencies operating or managing publicly accessible systems: you must implement comparable governance for agency-managed public content systems in scope. ¹

Operational scope (teams and systems)

You should assume AC-22 touches:

• Marketing/web team (CMS, web hosting, analytics tags that may expose data)
• Product/docs (documentation platforms, release notes)
• Support/customer success (knowledge base, ticketing portals)
• Engineering (repos, wikis, CI artifacts that may publish docs)
• Security/IT (domain/DNS ownership, storage configuration, incident comms)

A quick scoping test: If the URL can be accessed without authentication, it’s a candidate AC-22 system. If it can be indexed by search engines, treat it as high exposure.

What you actually need to do (step-by-step)

Step 1: Inventory all public content “posting paths”

Build a list of every mechanism that can publish or expose content publicly, including third-party platforms used under your control (CMS, docs host, status page vendor, public repo host). Track:

• System name and owner
• What content types can be posted
• Where access is administered (SSO, local accounts, admin console)
• How content is approved and published today
• Whether the system is inside the FedRAMP boundary or managed as a third party dependency

Output artifact: Public Content Systems Inventory (table is fine).

Step 2: Designate authorized publishers (and make it enforceable)

Define roles permitted to publish for each system (examples: “Web Publisher,” “Docs Maintainer,” “Status Page Publisher”). Then enforce it:

• Group-based access in IAM/SSO
• Least privilege: edit vs publish vs admin are distinct where the platform supports it
• Joiner/mover/leaver process ties into access provisioning and removal

Output artifacts:

• Role-to-system matrix (who can publish where)
• Access request and approval records for publisher roles

Step 3: Implement pre-publication review gates

Define what “review prior to posting” means for each system. Keep it simple and consistent:

• Content request created (ticket, change record, PR, or CMS workflow)
• Reviewer checks for nonpublic info (using a checklist)
• Approver records decision (approve/reject) before publication

Practical patterns that work:

• Docs/code-backed sites: require pull requests with at least one non-author approver; block direct pushes to publish branches.
• CMS-driven sites: require “draft → review → publish” workflow; restrict “publish” permission to a smaller group than “edit.”
• Status pages: require incident communications template and approval for postmortems and RCAs before public posting (often where internal details leak).

Output artifacts:

• Public Content Review Checklist (what reviewers look for)
• Workflow evidence (tickets, PR approvals, CMS approval logs)

Step 4: Define and execute a periodic public content review cadence

AC-22 requires a frequency you define. Pick a cadence you can sustain and evidence. Your review should cover:

• Random sample of recent posts from each system
• High-risk sections (download areas, logs, embedded screenshots, configuration snippets)
• Search engine results for your domains (to catch “forgotten” pages)
• Public repos for secrets and internal identifiers

Output artifacts:

• Review schedule (owner, frequency, scope)
• Completed review logs (date, reviewer, findings, actions)

Step 5: Create a removal and response playbook

“Remove nonpublic information if discovered” is not optional. Define:

• What qualifies as nonpublic exposure (tie to data classification)
• Who can take down content immediately (including after hours)
• How you preserve evidence (screenshots, URLs, timestamps) for incident tracking
• How you notify stakeholders (Security, Legal, customer/agency contacts as needed)
• How you prevent recurrence (training, template changes, permission hardening)

Output artifacts:

• Public Content Takedown SOP
• Remediation tickets and closure evidence

Step 6: Make it auditable in FedRAMP artifacts

AC-22 typically shows up in:

• SSP control implementation statements and boundary scoping narratives ²
• Procedures and screenshots for access controls and workflows
• Continuous monitoring evidence packages (review logs and any exceptions)

If you use Daydream to manage control operations, structure AC-22 as a recurring evidence task: publisher access reviews, periodic public content reviews, and incident/takedown records mapped to systems in your inventory. That keeps evidence from being scattered across web tools, ticketing, and repos.

Required evidence and artifacts to retain

Keep evidence that proves each of the four obligations:

AC-22 obligation	Evidence you should retain	What auditors look for
Authorized publishers designated	Role definitions, access matrices, SSO group membership lists, access approvals	Publishing authority is limited and intentional
Pre-publication review	PR approvals, CMS workflow logs, tickets with approvals, reviewer checklist	Review occurs before content becomes public
Periodic review at defined frequency	Review schedule, completed review logs, findings register	The frequency is defined and followed
Removal when discovered	Takedown tickets, timestamps, before/after screenshots, comms records	Fast containment and documented actions

Centrally store these in your GRC repository with clear naming so a 3PAO can sample quickly.

Common exam/audit questions and hangups

• “Show me who is authorized to publish to your public website/docs/status page.” Expect sampling: they will pick a system and ask for the list plus how it’s enforced. ¹
• “Demonstrate a pre-publication review for this specific page/post.” They’ll want the workflow record that predates publication.
• “What is your defined review frequency, and where is it documented?” “As needed” is a red flag because it is not a defined frequency.
• “Prove you performed the review.” A calendar is not enough; you need execution evidence.
• “What happens when you find nonpublic info?” They will look for a repeatable removal process and at least one example (even if it’s a tabletop or test record).

Frequent implementation mistakes (and how to avoid them)

1. Only covering the main website. Fix: inventory all public posting paths, including repos, docs, and ticket portals.
2. Relying on informal peer review. Fix: require recorded approval (ticket, PR, workflow log).
3. Defining a cadence but not retaining proof. Fix: standardize a review log template and store it in the same place every time.
4. Permissions drift. Fix: periodically review who has publish rights; remove stale access as part of your access governance.
5. Takedown without documentation. Fix: treat takedowns like incidents: capture URL, content, date/time, who approved removal, and follow-up actions.

Enforcement context and risk implications

No specific public enforcement cases were provided for this requirement in the source materials. The practical risk is straightforward: exposure of nonpublic information through public channels can create security incidents, contractual issues with agencies/customers, and negative assessor findings that delay authorization or create continuous monitoring findings. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Identify all publicly accessible systems and posting paths; assign an owner for each.
• Freeze and clean up publisher permissions on the highest-risk systems (website CMS, docs platform, status page, public repos).
• Publish a one-page procedure: who can publish, how review works, and what “nonpublic” includes for your organization. ¹

Days 31–60 (operationalize workflows and evidence)

• Implement pre-publication review gates per system (PR approvals, CMS workflow, ticket approvals).
• Create the review checklist and the review log template; train reviewers and publishers.
• Run the first full periodic review across all public systems; open remediation items for findings.

Days 61–90 (prove repeatability)

• Run the next scheduled review cycle and show trend closure on prior findings.
• Perform a publisher access revalidation (confirm business need; remove excess rights).
• Update SSP/control narratives and evidence pointers in your GRC system so assessors can sample quickly. ²

Frequently Asked Questions

What systems count as “publicly accessible” for AC-22?

Any system where information can be accessed without authentication, including websites, docs portals, status pages, public repos, and public support portals. Start with what you control, then include third-party platforms used to publish under your brand. ¹

Does AC-22 require a specific review frequency (weekly, monthly, quarterly)?

No. AC-22 requires an organization-defined frequency and evidence that you follow it. Pick a cadence you can sustain, document it, and keep completed review logs. ¹

What counts as “review prior to posting” if we publish through Git?

A standard pattern is mandatory pull requests with at least one independent approver before merge to the publishing branch. Keep PR approval logs and link them to the resulting public release. ¹

How do we handle emergency public communications (for example, status page updates)?

Define an “expedited posting” path with a narrower set of authorized publishers and a short approval step (even if it’s a second set of eyes in chat plus a ticket). Follow up with a retrospective review and document it. ¹

Do we need to scan for secrets in public repos to satisfy AC-22?

AC-22 does not prescribe tools, but it does require periodic review of publicly accessible content for nonpublic information. If repos are part of your public footprint, a repeatable review method (manual or automated) with logs supports the requirement. ¹

What evidence is most likely to fail an audit?

Missing proof of execution. Teams often have a policy that says reviews happen, but they cannot produce review logs, approval records, or takedown documentation for sampled content. ¹

Footnotes

1. NIST Special Publication 800-53 Revision 5

2. FedRAMP documents and templates

3. NIST SP 800-53 Rev. 5 PDF