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NET-36: API Gateway

NET 7 — High Protect

Mechanisms exist to implement an Application Programming Interface (API) Gateway, or similar technology, to serve as a controlled entry point that manages interactions between client-facing requests and backend services.

Renumbered: Formerly CLD-04.1 in SCF 2025.4.

Control Question: Does the organization implement an Application Programming Interface (API) Gateway, or similar technology, to serve as a controlled entry point that manages interactions between client-facing requests and backend services?

US (1)
Framework Mapping Values
USA Federal DoD Zero Trust Execution Roadmap v1.1 3.4 3.4.1
APAC (1)
Framework Mapping Values
APAC Malaysia RMiT 2025 A5-E1(g)

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

Cloud Security (CLD) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with CLD domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Cloud management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.

Level 2 — Planned & Tracked

Cloud Security (CLD) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with CLD domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with CLD domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CLD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Cloud management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Cloud management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Cloud-based Technology Assets, Applications and/or Services (TAAS) are governed according to the same processes used for on-premises TAAS, where no formal, dedicated cloud governance process exists. ▪ Cloud requirements for interoperability between components (APIs) are identified and documented.

Level 3 — Well Defined

Network Security (NET) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with NET domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with NET domain capabilities are well-documented and kept current by process owners. ▪ A network security management team, or similar function, is appropriately staffed and supported to implement and maintain NET domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of network security operations (e.g., network management solution and log aggregator). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with NET domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ Secure Baseline Configurations (SBC) enforce the principles of least privileges and least functionality for boundary protection technologies. ▪ An implemented and operational capability exists to implement an Application Programming Interface (API) Gateway, or similar technology, to serve as a controlled entry point that manages interactions between client-facing requests and backend services.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. NET-36_A01 an Application Programming Interface (API) Gateway, or similar technology, serves as a controlled entry point that manages interactions between client-facing requests and backend services.

Evidence Requirements

E-WEB-02 Client-Facing Web Services Protections

Documented evidence of protections for client-facing web services, including Strong Customer Authentication (SCA) and secure web traffic.

Website Security

Technology Recommendations

Micro/Small

  • Note: Typically not required at this size; cloud provider API gateway if APIs are exposed

Small

  • Cloud API gateway (e.g., AWS API Gateway, Azure API Management) for exposed APIs

Medium

  • API gateway as controlled entry point (e.g., Kong, Azure APIM, AWS API Gateway)
  • Authentication, throttling and logging at the gateway

Large

  • Enterprise API gateway/management platform (e.g., Apigee, MuleSoft, Kong Enterprise)
  • Centralized API policy enforcement
  • WAF integration

Enterprise

  • Enterprise API management with gateways across environments (e.g., Apigee, Kong, Azure APIM)
  • Zero-trust API access
  • API security analytics

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