If your cloud service is aiming to work with U.S. federal agencies, FedRAMP certification is a critical requirement. But the road to authorization can feel overwhelming without clear guidance. This step-by-step guide breaks down the FedRAMP process into manageable phases, helping you understand what to expect, how to prepare, and who to involve at each stage. Whether you're new to federal compliance or already managing multiple regulatory frameworks, this article will help you take the right next steps toward FedRAMP certification.
What You’ll Learn:
- The two main authorization pathways
- Required documentation and assessment steps
- The role of readiness assessments and continuous monitoring
- Key compliance challenges and how to overcome them
FedRAMP Compliance: Why It Matters
If you offer cloud-based services to U.S. federal agencies, FedRAMP certification is not optional—it is required. But for startups and seasoned providers alike, navigating FedRAMP’s complex process can be daunting. This guide walks through each step with clarity, from classification and documentation to authorization and monitoring. Whether you're pursuing a Joint Authorization Board (JAB) P-ATO or an Agency ATO, this article breaks down the most important things you need to know.
Step 1: Determine Your Impact Level
FedRAMP follows the NIST FIPS 199 standard to classify cloud systems as Low, Moderate, or High impact based on the potential consequences of a data breach to Confidentiality, Integrity, and Availability (CIA) of the system. Here’s how they compare:
|
Impact Level |
Typical Use Cases |
Type of Data |
Security Control Baseline |
|
Low Impact |
Public-facing systems, basic services with minimal sensitivity |
Public or non-sensitive information (e.g., open data portals, basic SaaS tools) |
~125 controls |
|
Moderate Impact |
Internal agency operations, most mission-support systems |
Controlled Unclassified Information (CUI), sensitive but unclassified data |
~325 controls |
|
High Impact |
Mission-critical, life-or-death, or national security systems |
Health records, law enforcement, emergency services, financial or defense data |
~421 controls |
Step 2: Choose Your Authorization Pathway
There are two FedRAMP authorization pathways:
- JAB Provisional Authority to Operate (P-ATO): Coordinated through the FedRAMP PMO and reviewed by the JAB (comprising GSA, DoD, and DHS). Limited availability but offers broad reusability.
- Agency Authority to Operate (ATO): Involves securing a sponsor agency and aligning to their security needs. Greater flexibility and typically faster to initiate.
A side-by-side comparison can help identify which route fits your goals and existing agency relationships.
|
Criteria |
Agency Authorization Path |
JAB Authorization Path |
|
Initiating Party |
CSP works directly with a federal agency sponsor. |
CSP is selected by the JAB through a competitive process. |
|
Sponsorship Required |
Yes, must have a confirmed federal agency sponsor. |
No specific agency required at the start, JAB acts as the sponsor. |
|
Selection Process |
Open to any CSP that can find an agency sponsor. |
Highly selective, JAB selects only 12 CSPs per year. |
|
Speed & Flexibility |
Potentially faster if the agency is engaged and experienced. |
Longer due to strict prioritization and deeper review process. |
|
Control Over Timeline |
More control, timeline is set between the CSP and agency. |
Less control, JAB sets the schedule and priorities. |
|
Post-Authorization Visibility |
Listing on the FedRAMP Marketplace after ATO granted by the agency. |
Listing on the FedRAMP Marketplace with JAB P-ATO, viewed as a high-trust credential. |
|
Level of Scrutiny |
May vary by agency; generally thorough but more flexible. |
Consistently rigorous, JAB includes GSA, DoD, and DHS oversight. |
|
Best For |
CSPs with strong agency relationships or a narrow agency use case. |
CSPs offering broadly useful services for many agencies and with significant security maturity. |
Step 3: Conduct a Readiness Assessment
For JAB authorization, a formal Readiness Assessment Report (RAR) conducted by an accredited 3PAO is required. For the Agency path, a readiness assessment is optional but highly recommended to identify potential compliance gaps early. This process evaluates your system’s security posture, documentation completeness, and implementation status.
Step 4: Complete the Full Security Assessment
Once ready, a FedRAMP 3PAO performs an in-depth assessment. This includes:
- Reviewing the System Security Plan (SSP)
- Testing security controls
- Documenting findings in a Security Assessment Report (SAR)
- Creating a Plan of Action and Milestones (POA&M) for remediation
These artifacts are submitted to the JAB or sponsoring agency for review.
Step 5: Authorization and Continuous Monitoring
After remediation, systems are either granted a JAB P-ATO or an Agency ATO. Authorization is not the end of your compliance journey. Monthly vulnerability scans, incident reporting, and annual reassessments are required. Strong continuous monitoring is crucial to maintaining authorization.
In Summary: FedRAMP Certification Made Simple
With the right preparation and expert guidance, FedRAMP doesn’t have to be overwhelming. Identify your impact level, choose your authorization path, document thoroughly, and engage with an experienced 3PAO early.
The most important key takeaways from this article:
- FedRAMP compliance is essential for serving U.S. federal clients
- Most providers will pursue Moderate-level certification
- Choosing the right path, JAB or Agency, depends on your partnerships and priorities
- Continuous monitoring is required to maintain authorization status