What qualifies as an IaaS is surprisingly broad: “Any product or service offered to a consumer, including complimentary or “trial” offerings, that provides processing, storage, networks, or other fundamental computing resources, and with which the consumer is able to deploy and run software that is not predefined, including operating systems and applications. The consumer typically does not manage or control most of the underlying hardware but has control over the operating systems, storage, and any deployed applications. The term is inclusive of “managed” products or services, in which the provider is responsible for some aspects of system configuration or maintenance, and “unmanaged” products or services, in which the provider is only responsible for ensuring that the product is available to the consumer.”
And it doesn’t stop there. The term IaaS includes all ‘virtualized’ products and services where the computing resources of a physical machine are shared, such as Virtual Private Servers (VPS). It even covers ‘baremetal’ servers allocated to a single person. The definition also extends to any service where the consumer does not manage or control the underlying hardware but contracts with a third party for access. “This definition would capture services such as content delivery networks, proxy services, and domain name resolution services,” the proposal reads. The proposed rule, National Emergency with Respect to Significant Malicious Cyber-Enabled Activities, will stop accepting comments from interested parties on April 30, 2024.