Cloud Security

FedRAMP Rev. 5

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At a Glance
FedRAMP Rev. 5 – Low / Moderate / High
  • Classification
    Category
    Cloud Security
    Domain
    Cloud Security
    Framework Family
    FedRAMP
  • Regulatory Context
    Type
    Certification / Assurance Program
    Legal Instrument
    Program
    Sector
    Government Sector
    Industry
    Government & Public Sector
  • Region / Publisher
    Region
    North America
    Region Detail
    United States
    Publisher
    FedRAMP Program Management Office, General Services Administration (GSA); governed by the FedRAMP Board under OMB policy
  • Versioning
    Version
    Rev5 (May 2023 baselines)
    Effective Date
    May 30, 2023
    Issue Date
    May 30, 2023
  • Adoption
    Adoption Model
    Regulatory Compliance
    Implementation Complexity
    High
  • Official Reference
License Information

License included / downloadable: Yes

The FedRAMP rules, baselines and legacy templates are U.S. government works published free of charge on fedramp.gov; the NIST SP 800-53 Rev. 5 catalog they select from is also free.

Framework text is licensed by its publisher and is included only where stated above.

Official Resources
FedRAMP Authorization Process Guide
Provides a comprehensive outline of the FedRAMP authorization process for cloud service providers.
FedRAMP Continuous Monitoring Strategy Guide
Outlines strategies for continuous monitoring of cloud services under FedRAMP.
FedRAMP Security Controls Baseline
Describes the baseline security controls necessary for FedRAMP compliance.
FedRAMP Plan of Action and Milestones Template Guide
Outlines the template for managing corrective actions for non-compliant security controls.
Key takeaways
  • FedRAMP Rev5 is the legacy FedRAMP certification type built on NIST SP 800-53 Revision 5 baselines: Low 156, Moderate 323, High 410 controls.
  • It has applied to every provider seeking authorization since the Rev5 baselines were released on May 30, 2023.
  • Under the Consolidated Rules for 2026, new Rev5 applications close June 11, 2027 and existing certifications stay active until at least December 31, 2028.
  • The FedRAMP Board replaced the Joint Authorization Board in May 2024, and OMB M-24-15 reset the program's scope and governance.
  • A provider implements the baseline, documents a System Security Plan, is tested by a 3PAO, and obtains an agency Authority to Operate.

Overview

FedRAMP Rev5 is the legacy FedRAMP certification type: the NIST SP 800-53 Revision 5 control baselines (Low 156 controls, Moderate 323, High 410, plus the Tailored LI-SaaS variant) and the documented, agency-sponsored assessment process that a cloud service offering must pass before U.S. federal agencies may use it for federal information. It has applied to every provider seeking a FedRAMP authorization since the Rev5 baselines were released on May 30, 2023. Under the Consolidated Rules for 2026 it is being replaced by FedRAMP 20x: FedRAMP stops accepting new Rev5 applications on June 11, 2027, and existing Rev5 certifications stay active until at least December 31, 2028.

FedRAMP itself was created by an OMB memorandum of December 8, 2011, written into law by the FedRAMP Authorization Act (section 5921 of Public Law 117-263, December 23, 2022, codified at 44 U.S.C. 3607 to 3616) and run by the FedRAMP Program Management Office within the General Services Administration (GSA). The FedRAMP Board, up to seven senior officials including members from DoD, DHS and GSA, replaced the Joint Authorization Board in May 2024, and OMB Memorandum M-24-15 of July 25, 2024 rescinded the 2011 memo and reset the program's scope and governance.

A provider categorizes its offering under FIPS 199, implements the matching baseline, documents it in a System Security Plan, has a FedRAMP-recognized third party assessment organization (3PAO) test it, and obtains an agency Authority to Operate that FedRAMP reviews before listing the service as FedRAMP Certified on the Marketplace. It then runs continuous monitoring: monthly POA&M, inventory and vulnerability scan deliverables, significant change notifications and an independent assessment at least annually (controls CM-8, RA-5, CA-2). From January 1, 2027 every Rev5 offering must also follow the 2026 rules.

Why does it matter?

FedRAMP is the only route by which a commercial cloud service becomes usable across the federal government, and agencies are required by law and OMB policy to use it and to reuse existing packages rather than repeat an assessment (44 U.S.C. 3613). Rev5 is the path most of the 543 certified services on the Marketplace hold today, so providers need to know both what the legacy process demands and how the 2026 rules change it.

Key benefits include:

  • One package, reused government-wide

Section 3613 of title 44 creates a presumption that a FedRAMP authorization package is adequate for an agency's own authorization to operate, so an agency reuses the assessment instead of commissioning a new one.

  • Baselines fixed by impact level

The Rev5 Security Controls Baseline sets 156 controls for Low, 323 for Moderate and 410 for High across 18 NIST SP 800-53 families, with FedRAMP-defined parameters such as a quarterly review of privileged accounts at Moderate (AC-2(j)).

  • Independent testing

A 3PAO, accredited under A2LA requirements, tests the implementation and writes the Security Assessment Report; an advisory 3PAO cannot assess the same system.

  • A single public register

The FedRAMP Marketplace lists each offering with its certification type (Rev5 or 20x), path (Agency or Program), class and status: Initial Implementation, FedRAMP Ready (legacy), In Process or Certified.

  • A known end date

New Rev5 applications close on June 11, 2027, and the 2026 rules state that existing Rev5 certifications remain active until at least December 31, 2028, which lets providers plan the move to 20x.

How does it work?

The authorization lifecycle starts with a FIPS 199 categorization of the federal information the service will hold. The provider implements the Low, Moderate or High baseline, records how each control is met in the System Security Plan and its appendices, and may first obtain FedRAMP Ready status through a 3PAO Readiness Assessment Report. An initial agency partner then sponsors the assessment: the 3PAO writes a Security Assessment Plan, tests the system, and reports findings in a Security Assessment Report and Risk Exposure Table.

The agency authorizing official reviews the package and issues an Authority to Operate; the provider uploads the package and the FedRAMP Initial Authorization Package Checklist to the secure repository (Low and Moderate) or its own repository (High), and the FedRAMP review team checks it before the Marketplace shows FedRAMP Certified. Each agency that later adopts the service issues its own ATO and sends a copy to GSA (44 U.S.C. 3613(c)).

Continuous monitoring keeps the certification alive. CM-8 requires an inventory updated at least monthly, RA-5 drives monthly vulnerability scanning, CA-2 requires an independent assessment at least annually, and CA-7 requires providers with several agency customers to run collaborative continuous monitoring. Under the Consolidated Rules for 2026 the System Security Plan becomes a Certification Package Overview and Security Decision Record, POA&Ms become a list of Accepted Weaknesses, templates give way to JSON data, and most FedRAMP-defined parameters are removed so that providers set their own organization-defined values.

Key Elements

  • Statutory basis (44 U.S.C. 3607 to 3616)

Section 3608 establishes FedRAMP within GSA as a standardized, reusable approach to security assessment and authorization for cloud products that process unclassified federal information; section 3611 requires independent assessment; section 3614 assigns OMB's guidance role.

  • FedRAMP Board (section 3610)

Not more than seven senior officials appointed by the OMB Director, including representatives of DoD, DHS and GSA, who set and update authorization requirements consistent with NIST standards and review agency determinations.

  • Rev5 baselines

Low 156, Moderate 323 and High 410 controls selected from NIST SP 800-53 Rev. 5, with FedRAMP parameters and additional requirements; LI-SaaS reuses the Low list with tailoring actions.

  • Certification package

Legacy: SSP with appendices A to Q, SAP, SAR, POA&M (SSP Appendix O) and the agency ATO letter. 2026 rules: Certification Package Overview, Security Decision Record and Secure Configuration Guide.

  • Marketplace designations

FedRAMP Ready (3PAO Readiness Assessment Report accepted), FedRAMP In Process (actively working with an agency) and FedRAMP Certified (package reviewed and listed for government-wide use).

  • Consolidated Rules for 2026

Fifteen Rev5 rulesets (for example Collaborative Continuous Monitoring, Vulnerability Evaluation and Reporting, Significant Change Notification, Cryptographic Module Use) that took effect on July 4, 2026 and are enforced from January 1, 2027.

What does it cover?

Rev5 applies to cloud service offerings that federal agencies use for federal information, to the 3PAOs that assess them and to the agencies that sponsor, authorize and reuse them. It covers Infrastructure, Platform and Software as a Service at the Low, Moderate and High impact levels and the LI-SaaS tailored case. Under the 2026 rules Rev5 remains the required type for Class D (High) and for standalone offerings that run their own infrastructure, while cloud-native services built on FedRAMP-certified platforms are steered to 20x.

What are its objectives?

FedRAMP Rev5 exists to give agencies one trusted assessment of a cloud service that every agency can reuse.

Apply the NIST SP 800-53 Rev. 5 baselines consistently to every cloud service that holds federal information.

Require independent testing by a FedRAMP-recognized 3PAO before an agency authorizes use.

Make one authorization package reusable across agencies through the Marketplace and the secure repository.

Keep each certified service under continuous monitoring with monthly deliverables and annual reassessment.

Carry providers across to FedRAMP 20x before the Rev5 type is retired.

Framework in Context

FedRAMP operates inside FISMA: agencies still authorize each system under 44 U.S.C. 3554, and the baselines are the NIST SP 800-53 Rev. 5 catalog selected by FIPS 199 impact level. DoD maps FedRAMP baselines into its Cloud Computing Security Requirements Guide, and the FedRAMP Authorization Act sunsets five years after December 23, 2022 unless Congress acts. FedRAMP 20x, piloted at Low in 2025 and at Moderate in early 2026, replaces documented plans with measured Key Security Indicators.

Common Framework Mappings

Organizations map FedRAMP Rev. 5 to other established frameworks to simplify cloud authorization, harmonize controls, support audits, and demonstrate multi-framework compliance across cloud security and privacy programs.

Mapped frameworks include:

CIS Controls v8.1

CSA STAR

ISO 27001:2022

ISO 27017

ISO 27018

NIST 800-37 Rev.2

NIST 800-53 Rev.5

SOC 2

SMARTSUITE

How SmartSuite Supports FedRAMP Rev. 5

SmartSuite provides the system for managing controls, evidence, mappings, assessments, and reporting.

Use Compliance Management to hold the Rev5 baseline for your offering as a control library with owners, implementation statements, testing and evidence, and Cyber & IT Risk to track the vulnerabilities, findings and risk decisions that feed the monthly deliverables and the annual assessment.

Baseline Control Library

Load the 156, 323 or 410 Rev5 controls by NIST family with the FedRAMP parameter, the implementation statement and the inherited or customer-responsibility flag for each.

Security Decision Record

Log each organization-defined parameter and risk decision with its rationale, approver and date, the record the 2026 rules require in place of FedRAMP-set values.

Findings and Accepted Weaknesses

Track 3PAO findings, deviation requests and remediation to closure, and report the open list that replaces the POA&M under the Consolidated Rules.

Monthly Deliverables Calendar

Schedule the inventory update (CM-8), vulnerability scan reports (RA-5) and POA&M upload due each month and record when each agency reviewed them.

Significant Change and Incident Log

Route significant change notifications and incident communications to the agency authorizing officials with the evidence and approvals attached.

ATO and Assessment Evidence

Keep the SSP or Certification Package Overview, SAP, SAR, each agency ATO letter and the annual assessment artifacts linked to the controls they cover.

Related frameworks

CIS Controls v8.1

CIS Controls v8.1 is a prioritized set of 18 Controls and 153 Safeguards, in three Implementation Groups, with a new Govern function.

CSA STAR

CSA STAR is the Cloud Security Alliance's public registry for cloud assurance: a CAIQ self-assessment at Level 1, an ISO/IEC 27001 or SOC 2 audit at Level 2, built on CCM v4.1.

ISO 27001:2022

ISO/IEC 27001:2022 specifies requirements for an information security management system: Clauses 4 to 10, risk treatment, the Statement of Applicability and 93 Annex A controls.

ISO 27017

ISO/IEC 27017:2026 gives cloud security control guidance for customers and providers, built on ISO/IEC 27002:2022, with four cloud-specific controls; it replaced the 2015 edition.

ISO 27018

ISO/IEC 27018:2025 gives guidelines for protecting PII in public clouds acting as PII processors, built on ISO/IEC 27002:2022 with an extended control set.

NIST 800-37 Rev.2

NIST SP 800-37 Rev. 2 is the NIST Risk Management Framework: seven steps from Prepare to Monitor, with the tasks, roles and authorization decisions federal agencies apply under OMB A-130.

NIST 800-53 Rev.5

NIST SP 800-53 Rev. 5 is the NIST catalog of security and privacy controls in 20 families, mandatory for federal systems under OMB A-130 and FISMA; Release 5.2.0 issued August 27, 2025.

SOC 2

SOC 2 is the AICPA examination, under AT-C 105 and 205, of a service organization's controls against the 2017 Trust Services Criteria, issued as a type 1 or type 2 attestation report.

FAQ

Frequently Asked Questions For FedRAMP Rev. 5 (Federal Risk and Authorization Management Program)

Yes, until June 11, 2027, when FedRAMP stops accepting new Rev5 certification applications. New Rev5 applications made from January 1, 2027 must already follow the Consolidated Rules for 2026, and FedRAMP advises providers to consider 20x first because it is retiring Rev5 as a certification type.

FedRAMP is a program within the General Services Administration under the FedRAMP Authorization Act (44 U.S.C. 3608). The FedRAMP Board of up to seven agency officials sets the requirements (section 3610). Under the Rev5 agency path a federal agency authorizing official issues the Authority to Operate, and FedRAMP reviews the package before listing the service as FedRAMP Certified.

The FedRAMP Security Controls Baseline lists 156 controls for Low, 323 for Moderate and 410 for High, selected from NIST SP 800-53 Rev. 5 across 18 control families. The Tailored LI-SaaS baseline uses the same 156 controls as Low with tailoring actions that let the provider attest to many of them.

The provider uploads an updated inventory and POA&M and vulnerability scan reports each month (controls CM-8 and RA-5), reports incidents and significant changes, and has an independent assessment at least annually (CA-2). Providers with more than one agency customer run collaborative continuous monitoring (CA-7). The 2026 rules replace the POA&M with a list of Accepted Weaknesses.

Yes. Section 3613 of title 44 presumes that the controls and materials in a FedRAMP authorization package are adequate for an agency's own authorization to operate, and requires agencies to reuse existing assessments to the extent practicable. Each agency still issues its own ATO and sends a copy to GSA.

Put this framework to work in SmartSuite

Manage controls, risks, evidence, and audits in one platform designed for modern governance, risk, and compliance.