FedRAMP Compliance for Cloud Service Providers

The gateway to government cloud

If you're a cloud service provider (CSP) and you want to sell to the US federal government, there's one acronym you need to know: FedRAMP.

The Federal Risk and Authorization Management Program is a government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. In plain English: it's how the government ensures cloud vendors are secure enough to handle federal data.

FedRAMP authorization is your ticket to the federal market—a market worth billions in annual cloud spending. But let's be clear: FedRAMP is not for the faint of heart. It's rigorous, expensive, and time-consuming. For the right companies, however, it opens doors that no other certification can.

What FedRAMP actually requires

FedRAMP is based on NIST Special Publication 800-53, the federal standard for security controls. Depending on your authorization level, you'll implement between 125 and 421 controls across 20 control families.

The 20 control families

Family	Description
Access Control (AC)	Manage who can access what
Awareness and Training (AT)	Security training requirements
Audit and Accountability (AU)	Logging and monitoring
Assessment, Authorization, and Monitoring (CA)	Continuous assessment
Configuration Management (CM)	System configuration and change control
Contingency Planning (CP)	Business continuity and disaster recovery
Identification and Authentication (IA)	Identity management and MFA
Incident Response (IR)	Detecting and responding to incidents
Maintenance (MA)	System maintenance procedures
Media Protection (MP)	Protecting storage media
Physical and Environmental Protection (PE)	Facility security
Planning (PL)	Security planning documentation
Program Management (PM)	Governance and oversight
Personnel Security (PS)	Employee security requirements
PII Processing and Transparency (PT)	Privacy requirements
Risk Assessment (RA)	Identifying and assessing risks
System and Services Acquisition (SA)	Procurement and development security
System and Communications Protection (SC)	Network and data protection
System and Information Integrity (SI)	Malware protection, monitoring, alerts
Supply Chain Risk Management (SR)	Third-party risk

Each control family contains multiple individual controls, and each control has specific implementation requirements.

The three impact levels

FedRAMP authorizations come in three flavors, based on the sensitivity of data being processed:

FedRAMP Low

For: Cloud services handling low-impact data

Data types: Publicly available data, data that wouldn't cause significant harm if breached

Control count: ~125 controls

Examples: Public-facing websites, basic collaboration tools

Typical timeline: 6–12 months

Cost range: $250,000–$500,000+

FedRAMP Moderate

For: Cloud services handling moderate-impact data (most common)

Data types: Sensitive but unclassified data, PII, some law enforcement data

Control count: ~325 controls

Examples: Email systems, case management, financial systems

Typical timeline: 12–18 months

Cost range: $500,000–$2,000,000+

FedRAMP High

For: Cloud services handling high-impact data

Data types: Law enforcement data, healthcare data, financial data, life safety data

Control count: ~421 controls

Examples: Critical infrastructure systems, emergency services, healthcare systems

Typical timeline: 18–24+ months

Cost range: $1,000,000–$5,000,000+

Most commercial cloud providers pursuing FedRAMP target Moderate, as it covers the majority of federal use cases.

The two paths to authorization

There are two ways to achieve FedRAMP authorization:

Agency Authorization (Agency ATO)

How it works:

1. Find a federal agency willing to sponsor you
2. Work with that agency through the authorization process
3. Agency's Authorizing Official (AO) grants authorization
4. Authorization can be reused by other agencies

Pros:

• Often faster if you have an agency relationship
• Agency guidance throughout the process
• Lower upfront risk (you have a customer)

Cons:

• Dependent on finding a sponsor
• Agency timelines can be unpredictable
• May need to prioritize agency-specific requirements

JAB Authorization (Joint Authorization Board)

How it works:

1. Apply to be prioritized by the FedRAMP PMO
2. Work with a 3PAO (Third-Party Assessment Organization)
3. The JAB (DoD, DHS, GSA) reviews and authorizes
4. Receive a Provisional Authorization to Operate (P-ATO)

Pros:

• Highest level of government endorsement
• Broader market acceptance
• More structured process

Cons:

• Competitive selection process
• Longer timelines
• No agency sponsor to guide you

Which path is right for you?

Choose Agency if:

• You already have a federal customer interested in your product
• You want faster time-to-market
• Your use case is agency-specific

Choose JAB if:

• You want the broadest possible market access
• You're willing to invest more time for higher recognition
• You don't have an existing agency relationship

The authorization process

Regardless of path, FedRAMP authorization follows these phases:

Phase 1: Preparation

Duration: 2–6 months

Activities:

• Gap assessment against FedRAMP requirements
• System boundary definition
• Security documentation development
• Control implementation
• 3PAO selection

Key deliverables:

• System Security Plan (SSP)
• Policies and procedures
• Control implementation evidence

Phase 2: Assessment

Duration: 3–6 months

Activities:

• 3PAO conducts Security Assessment
• Vulnerability scanning and penetration testing
• Interview staff and review documentation
• Identify and document findings

Key deliverables:

• Security Assessment Report (SAR)
• Penetration test report
• Findings and risk assessment

Phase 3: Authorization

Duration: 2–4 months

Activities:

• Address assessment findings
• Submit package to agency or JAB
• Review and adjudication
• Receive Authorization to Operate (ATO) or P-ATO

Key deliverables:

• Plan of Action and Milestones (POA&M)
• Final authorization package
• ATO/P-ATO letter

Phase 4: Continuous monitoring

Duration: Ongoing

Activities:

• Monthly vulnerability scanning
• Annual penetration testing
• Continuous control monitoring
• Monthly/annual reporting
• Significant change management

Key deliverables:

• Monthly scan reports
• Annual assessments
• Incident reports (as needed)
• Continuous monitoring reports

The documentation challenge

FedRAMP requires extensive documentation. The core documents include:

System Security Plan (SSP)

The SSP is your master document—typically 300–500+ pages. It describes:

• System architecture and boundaries
• Data flows
• How each control is implemented
• Roles and responsibilities
• Security configurations

This is the document that takes the most effort to create and maintain.

Policies and procedures

You need documented policies covering every control family:

• Access control policy
• Audit and accountability policy
• Configuration management policy
• Contingency planning policy
• Incident response policy
• And many more...

Each policy needs corresponding procedures that describe how you implement it.

Additional required documents

• Contingency Plan (CP)
• Incident Response Plan (IRP)
• Configuration Management Plan (CMP)
• Information Security Continuous Monitoring (ISCM) Strategy
• Privacy Impact Assessment (PIA)
• Rules of Behavior
• User guides and training materials

What this means for small cloud providers

Let's be honest: FedRAMP is primarily designed for larger cloud providers with dedicated compliance teams and significant resources. The costs and complexity are substantial.

However, there are paths for smaller providers:

FedRAMP Tailored (Li-SaaS)

For Low-Impact SaaS solutions, FedRAMP offers a streamlined authorization path:

• Reduced control set
• Lower assessment costs
• Faster timeline
• Still requires 3PAO assessment

If your solution is Low-Impact, this may be viable for smaller organizations.

Partnering with authorized platforms

If your application runs on an already-authorized IaaS/PaaS (AWS GovCloud, Azure Government, Google Cloud Government), you inherit some controls from the underlying platform. This reduces your compliance burden.

StateRAMP

StateRAMP applies similar principles to state and local government. It's less rigorous than FedRAMP while still providing standardized security validation. For smaller providers, StateRAMP may be a stepping stone.

Focusing on documentation first

Even if full FedRAMP isn't feasible today, building FedRAMP-aligned documentation positions you for future authorization:

• Policies mapped to NIST 800-53
• Clear system boundaries
• Control implementation documentation
• Evidence collection practices

Common FedRAMP challenges

Organizations pursuing FedRAMP consistently struggle with:

Challenge 1: Documentation volume

The documentation requirements are immense. A complete FedRAMP package can exceed 1,000 pages. Many organizations underestimate the effort required.

Challenge 2: Control implementation

Some controls require significant technical implementation:

• FIPS 140-2 validated cryptography
• Continuous monitoring capabilities
• Multi-factor authentication everywhere
• Comprehensive logging and auditing

These may require architectural changes.

Challenge 3: Continuous monitoring burden

Authorization isn't the end—it's the beginning of continuous monitoring. Monthly vulnerability scanning, annual assessments, and ongoing reporting require dedicated resources.

Challenge 4: Cost and timeline

FedRAMP is expensive. Between 3PAO assessments, tool implementation, consultant support, and internal effort, costs easily reach six to seven figures. Timelines regularly exceed initial estimates.

Challenge 5: Change management

Once authorized, any "significant change" to your system requires assessment. This can slow down product development and release cycles.

How FedRAMP relates to other frameworks

If you're pursuing FedRAMP, how does it connect to other compliance frameworks?

FedRAMP and SOC 2

SOC 2 is often a stepping stone to FedRAMP. Many FedRAMP controls overlap with SOC 2 Trust Services Criteria. If you're already SOC 2 compliant, you've addressed some FedRAMP requirements.

See: SOC 2 Compliance

FedRAMP and ISO 27001

ISO 27001 provides a solid foundation for FedRAMP, particularly for governance and documentation practices. However, FedRAMP's technical requirements are more prescriptive.

See: ISO 27001 Compliance

FedRAMP and NIST CSF

NIST CSF is a simplified framework based on the same NIST publications that underpin FedRAMP. CSF alignment is a good starting point before tackling the full NIST 800-53 control set.

See: NIST CSF

FedRAMP and CMMC

If you're also in the defense industrial base, CMMC and FedRAMP have significant overlap (both draw from NIST). However, they're separate certifications with different assessment processes.

See: CMMC Compliance

Frequently asked questions

How much does FedRAMP authorization cost?

Total cost ranges widely:

• Low: $250,000–$500,000
• Moderate: $500,000–$2,000,000+
• High: $1,000,000–$5,000,000+

Costs include 3PAO assessment, consultant support, tool implementation, documentation, and internal effort.

How long does FedRAMP take?

Realistic timelines:

• Low/Li-SaaS: 6–12 months
• Moderate: 12–18 months
• High: 18–24+ months

Add preparation time if you're starting from scratch.

Can startups get FedRAMP authorized?

Technically, yes. Practically, it's challenging. The costs and timeline require significant resources. Smaller companies often:

• Start with StateRAMP or FedRAMP Tailored
• Build on authorized infrastructure (AWS GovCloud, etc.)
• Partner with larger authorized providers
• Begin FedRAMP prep after securing Series B+ funding

What's a 3PAO?

A Third-Party Assessment Organization—an accredited firm that conducts FedRAMP assessments. They're independent evaluators who verify your controls work as documented.

Can we use our FedRAMP authorization for state/local?

FedRAMP authorization demonstrates strong security practices, but state and local agencies have their own requirements. StateRAMP is designed specifically for this market and may be more directly applicable.

What happens if we fail the assessment?

You don't "fail" in a binary sense. The 3PAO identifies findings, which you address through a Plan of Action and Milestones (POA&M). Significant findings may delay authorization, but remediation is expected as part of the process.

Where CyberPolicify fits

FedRAMP requires extensive documentation—policies, procedures, system security plans, and evidence. CyberPolicify helps with the documentation foundation:

NIST 800-53-aligned policies

Generate policies mapped to NIST 800-53 control families—the same controls that underpin FedRAMP. Start building compliant documentation before engaging a 3PAO.

Gap assessment

Run assessments against NIST 800-53 controls to identify gaps early. Understand what you need to implement before incurring assessment costs.

Documentation foundation

Create the policies, procedures, and control descriptions that form the basis of your System Security Plan. Reduce documentation effort with structured, framework-aligned content.

Cross-framework efficiency

If you're also pursuing SOC 2, ISO 27001, or CMMC, see how controls overlap. Build once, use for multiple compliance goals.

Scalable approach

Even if full FedRAMP isn't feasible today, building toward NIST 800-53 alignment positions you for future authorization—or for customers who reference federal security standards.

FedRAMP is a significant undertaking. Start with documentation that will serve you throughout the journey.