Checklist for FedRAMP Requirements

When the federal government adopted a “cloud-first” initiative to ease agency data burdens, it established the Federal Risk and Authorization Management Program (FedRAMP). The program standardizes the security assessment process, authorization, and continuous monitoring processes for cloud products and services used by federal agencies. Although many assume that FedRAMP authorization only applies to those who work with federal agencies, FedRAMP compliance benefits private sector businesses as well.

Who Should Be FedRAMP Compliant?

Any cloud service provider (CSP) that wants to do business with U.S. federal agencies must be FedRAMP compliant. This includes meeting strict requirements for security assessment, authorization, and continuous monitoring, ultimately leading to an Authorization to Operate (ATO) from a sponsoring agency or a Provisional ATO (P-ATO) from the Joint Authorization Board (JAB).

In 2022, the FedRAMP Authorization Act was signed into law as part of the National Defense Authorization Act (NDAA). This formalized FedRAMP and streamlined the authorization process by encouraging reuse of existing authorizations. It also created a Federal Secure Cloud Advisory Committee to improve oversight and collaboration between public and private sectors.

Even if you’re not currently part of the FedRAMP Marketplace or working with government agencies, adopting FedRAMP-aligned controls is still a strategic move. As supply chain security and data protection expectations grow in the private sector, FedRAMP compliance is a strong signal of trust and operational maturity.

FedRAMP Security Impact Levels: Low, Moderate, and High Explained

Impact levels are based on the potential consequences of a breach in three key areas: confidentiality, integrity, and availability of the system’s data.

Low Impact: The loss of confidentiality, integrity, or availability would have limited adverse effects. This is typical for public-facing systems with no sensitive information (e.g., marketing websites).
Moderate Impact: A loss here would result in serious adverse effects—for example, if personal data is involved. Most SaaS companies working with federal agencies fall into this category.
High Impact: A breach would cause severe or catastrophic effects, such as threats to life, national security, or economic stability. Systems supporting healthcare, law enforcement, or emergency services often require this level of protection.

These categories are assessed using the FIPS 199 security standard, which guides you in classifying systems based on the highest impact across any of the three pillars.

Why This Classification Matters

Each level maps to a different FedRAMP security control baseline with varying volumes of controls.

Low Baseline: ~125 controls
Moderate Baseline: ~325 controls
High Baseline: ~421 controls

This impacts how extensive your SSP, Risk Management Plan, and control implementation efforts must be. It also determines the intensity of your continuous monitoring and audit obligations.

Before beginning a FedRAMP project, conduct an internal impact assessment or engage with an accredited third-party assessment organization (3PAO) to confirm your categorization. Misclassifying your impact level can set your project timeline back by months.

FedRAMP Requirements Checklist

FedRAMP compliance can be complex and requires significant commitment. This checklist is a high-level overview of the main requirements for cloud service providers. Each item has numerous sub-tasks and detailed requirements. Depending on the cloud offering and its impact level, certain controls or requirements might differ.

System Security Plan (SSP):
- Detailed documentation describing all the security controls you’ve implemented in your security posture.
- System overview, system boundaries, system environment, and system data flow diagrams.
Security Assessment Plan (SAP):
- Document detailing the planned FedRAMP assessment efforts.
- Identification of security controls to be tested, assessment procedures, and expected outcomes.
Security Assessment Report (SAR):
- A report that details the results of the security assessment.
- Identification of vulnerabilities, risks, and recommendations.
Plan of Action and Milestones (POA&M):
- Document identifying risks and plans for mitigation.
- Explanation of how and when vulnerabilities identified in the SAR will be addressed.
Continuous Monitoring Strategy & Plan:
- A strategy for ongoing monitoring of security controls.
- Includes the frequency and methods of testing, roles and responsibilities, and reporting requirements.
Training: Ensure all personnel have adequate security training.
Implement NIST Security Controls: Implement the security controls specified in NIST Special Publication 800-53, based on the system’s impact level (Low, Moderate, or High).
Third-Party Assessment Organization (3PAO):
- Engage a 3PAO to perform an independent assessment of your security controls and provide an objective SAR.
Authorization Package: Submit the package to the appropriate governing body (Joint Authorization Board (JAB) or an agency) for a Provisional Authorization to Operate (P-ATO) or an Authorization to Operate (ATO).
Incident Reporting: Establish a process for reporting security incidents to FedRAMP and other relevant agencies within specified timeframes.
Continuous Monitoring: Commit to ongoing monitoring and regular reporting of security control effectiveness.
FedRAMP Package Repository: Use the secure repository to submit documentation and updates.
Periodic Assessments: Undergo periodic reassessment (typically every three years) to ensure ongoing compliance.
Engage with FedRAMP PMO (Program Management Office): Ensure open communication with the PMO and adhere to guidance and feedback.
Policies and Procedures: Establish and maintain comprehensive security and privacy policies and procedures in line with NIST and FedRAMP requirements.
Role-based Training: Ensure training is provided to staff based on their role within the organization and relevant to the cloud service offering.

Always refer to official FedRAMP documentation and resources or consult with experts when working towards compliance.

Why Do Non-CSPs Care About FedRAMP?

The shift to cloud computing is well underway. As shown by the recent Salesforce $8 billion acquisition of Informatica, cloud-based data services are the long game for managing, analyzing, and leveraging data.

Cloud-based services are still a primary target for hackers: 38% of IT leaders identify SaaS applications as the most targeted type of cloud service, with storage and email systems also under heavy attack. In 2024, over 230 million AWS environments were compromised due to cloud security misconfigurations like exposed environment variables. Your CSP may be the weakest link in your supply chain. FedRAMP compliance can enable you to control your business information system solutions better.

Why FedRAMP Is More Secure Than FISMA

The Federal Information Security Management Act (FISMA) guidelines can be used to review cloud services’ security controls. The Federal Information Procession Standard (FIPS) 199 ranks information based on the impact a vulnerability or breach has on your information system infrastructure. The FIPS 200 used by FISMA outlines minimum security control requirements. Finally, FISMA applies baseline security controls described in that National Institute of Standards and Technology (NIST) publication 800-53.

These controls sound great but come with a few problems FedRAMP solves.

FedRAMP focuses specifically on security elements unique to CSPs.
FedRAMP security controls go beyond the NIST baseline requirements.
FedRAMP requires a third-party assessment organization (3PAO) to certify the security controls.

If you’re a cloud services provider or someone seeking to engage a CSP in enabling business operations, these additional information security protections focus on threats specific to Infrastructure-as-a-Service (IaaS) providers.

How to Manage FedRAMP Requirements

Since FedRAMP was initially intended to govern CSPs working with the U.S. government, much of the federal information may be classified, and the requirements may feel burdensome. However, with CSPs increasingly targeted by hackers, these requirements protect anyone using a FedRAMP certified CSP. Although FedRAMP released a “Tips and Cues Compilation,” below is an easy to review the summary of the most critical steps to compliance.

Continuous Monitoring

Address every vulnerability found in your continuous monitoring program.
Remediate the vulnerability.
Establish a Deviation Request Process.
Justify findings as “Vendor Dependency” and establish a 30-day vendor contact timetable.
Align monthly monitoring scans and Plan of Action & Milestones (POA&M) to sync with your patch management program to report only real vulnerabilities not ones already scheduled for remediation.

Security Controls

Review for commonly overlooked or insufficiently answered controls.
When reviewing the “Implementing Configuration Settings (CM-6)” make sure to identify all system components requiring configuration management, individuals responsible for configuration, how responsible part configures, any additional FedRAMP requirements included, and where you saved the documentation.

Review for common missed or neglected FedRAMP or NIST requirements.
Not identifying portals, lacking multi-factor authentication, non-segregation of customers, high vulnerabilities detected during testing, unclear security authorization boundaries, incomplete or poorly defined policies and procedures are all examples of common documentation problems.

General Program

Communicate with your FedRAMP Information System Security Officer (ISSO) or government liaison.
A Cloud Service Offering (CSO) must be approved and granted FedRAMP Provisional Authorization to Operate or Agency ATO before leveraging security controls.
Use NIST SP 800-53 Revision 1 Contingency Planning Guide for Federal Information System Appendix B to create a Business Impact Analysis
If you are a moderate impact CSP and want to move into Law Enforcement, Emergency Services, Financial Systems, Health Systems, or any other high impact category, you should review the Categorization Change Form Template first.

Readiness Assessment Report (RAR)

Always send an email notification to info@fedramp.gov when submitting a RAR or RAR update, or authorization package to ensure review.

Security Assessment Plan (SAP) & Security Assessment Report (SAR)

If a 3PAO assessor validates/determines a finding a “False Positive” ensures that the JAB also approves those findings otherwise, they must be added to the Continuous Monitoring (ConMon) POA&M.
3PAO vulnerability scanning includes reviewing tools for configurations, ensuring scans meeting FedRAMP requirements, overseeing and monitoring scans, describing and executing procedures.
Penetration testing tools must be in the SAP and match the Penetration Test Plan document.
Document False Positives or corrected findings with specific items of evidence such as screenshots or scan files, list by file name, and include with the SAR.
Assign unique Vulnerability Identifiers and ensure previously documented vulnerabilities are not assigned new identifiers.

System Security Plan (SSP)

Security requirements for each control include a description of the solution, how it meets security control requirement, responsible parties, how often reviewed, who reviews, what triggers reviews, documentation of reviews, proof of review, any policies referenced as implementation reasons.
Review “Security Procedures” to include all steps for users, system operations personnel, or others.

Common FedRAMP Compliance Challenges

1. Limited In-House Expertise

FedRAMP is steeped in frameworks like NIST SP 800-53 and FIPS 199 assessments. If your team does not have experience in these areas, your organization will likely struggle with interpreting control requirements correctly or documenting them rigorously enough. Missteps here can delay your FedRAMP authorization process or result in failed assessments.

2. Fragmented Collaboration Across the Organization

FedRAMP compliance requires cross-functional coordination between engineering, product, legal, security, and compliance teams. Without a unified compliance requirements program in place, miscommunication and version control issues can result in conflicting documentation and missed responsibilities. Delayed remediation efforts are another critical risk.

3. Resource and Budget Constraints

Achieving compliance, especially for a Moderate or High impact level system, can take 6 to 18 months. Note that the costs are not just 3PAO assessments or toolsets. They also include staff time, hiring advisory services, internal training, and remediation work. Many organizations underestimate these costs or fail to secure ongoing support for continuous monitoring post-authorization.

4. Constantly Evolving Security Requirements

FedRAMP frequently updates its baselines and guidance based on emerging threats. CSPs must stay agile to adapt their systems, policies, and controls without starting over. For teams already stretched thin, this can feel like trying to hit a moving target—especially when juggling other security certifications like ISO 27001 or SOC 2.

5. Complex Risk Management Costs

One of the more under-discussed challenges is quantifying and managing the downstream risk of partial compliance. If you’re not fully FedRAMP authorized, federal buyers may not consider your product or you could be deemed non-competitive in highly regulated sectors like healthcare, finance, or public safety. The opportunity cost of delayed compliance is often steep, but hard to calculate.

FedRAMP Best Practices

1. Treat FedRAMP as a Program, Not a Project

Compliance shouldn’t be something you race to complete and then shelve. Build a long-term improvement program around FedRAMP that includes documentation versioning, automated control testing where possible, and executive reporting. Consider integrating your FedRAMP controls into your broader risk management framework so they remain visible and prioritized.

2. Leverage FedRAMP Advisory and Assessment Services Early

Engaging a FedRAMP advisory services provider before kicking off the process can help identify gaps in your system architecture, SSP narratives, and security governance. A good advisory partner can also act as a translator, bridging your internal control environment with FedRAMP’s expectations. This will save you countless hours during the assessment phase.

3. Define Authorization Strategy Early On

One of the biggest forks in the road is whether to pursue a JAB provisional authorization to operate or agency authorization to operate. Each has trade-offs in terms of visibility, sponsorship, timeline, and scrutiny. A well-informed authorization choice based on your federal customer pipeline, system impact level, and roadmap can help avoid wasted effort or costly pivots down the line.

4. Centralize Control Evidence and Workflows

Use a compliance platform or internal dashboard to track documentation, POA&M items, scan results, and policy changes in one place. This minimizes version control issues and simplifies audit prep. If you’re relying on spreadsheets and emails, you’re increasing your risk of missed controls and audit failures.

5. Upskill Your Team or Hire Specialized Talent

Technical expertise is non-negotiable. Whether it’s configuring compliant encryption settings or defending your control choices to a 3PAO, you need people who’ve done this before. If you don’t have them in-house, bring them in as consultants or fractional security leads.

How ZenGRC Enables FedRAMP Documentation

FedRAMP compliance requires more than a single security policy. The detailed control narratives and the wide array of 3PAO documentation necessary for establishing certification often hinder the process. Organization can streamline your process. Moreover, communication within your organization can help develop efficient reporting lines when multiple parties are responsible for different contingencies and controls.

Our compliance dashboards act as a “single source of truth” showing data and metrics that allow you to determine whether your controls align with regulatory requirements or whether you have compliance gaps.

With task prioritization, you can assign, audit, and track issues to stay on top of vulnerability management.

Using the SaaS platform, you can gather evidence more rapidly to streamline the audit process.
For more information about the role of ZenGRC in FedRAMP compliance and how it can ease your stress, contact us for a demo today.