The federal government is one of the largest buyers of cloud services in the world, representing a massive opportunity for Cloud Service Providers (CSPs). But to do business with federal agencies, you need to meet their stringent security standards. Enter FedRAMP.

If you are a cloud provider looking to unlock unprecedented growth, achieving FedRAMP compliance is your golden ticket. However, the framework is known for being complex, rigorous, and ever-evolving with the highly anticipated rollout of the FedRAMP 20x modernization initiative.

Here is your modern guide to understanding exactly what is FedRAMP, navigating its requirements, and preparing your business for the sweeping FedRAMP 20x changes on the horizon.

What is FedRAMP?

The Federal Risk and Authorization Management Program (FedRAMP) is a United States federal government-wide compliance program. It provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services.

Instead of agencies conducting redundant, individual security assessments for the same cloud product, FedRAMP establishes a "do once, use many times" framework. Once your cloud service is certified, any federal agency can leverage your solution with confidence, saving time and resources for both the government and your business.

How FedRAMP Authorization Works

At Rhymetec, we know firsthand that the road to FedRAMP can feel overwhelming. We streamline each phase to reduce friction and accelerate your journey to compliance. Typically, the authorization process involves:

  1. Scope Assessment: Defining your system boundaries and determining the exact scope of your cloud environment.
  2. Gap Assessment & Planning: Assessing your current controls against FedRAMP requirements and building a project plan to close any gaps.
  3. Policy & Control Implementation: Creating and operationalizing all required FedRAMP-aligned policies, procedures, documentation, and technical safeguards.
  4. Audit Preparation & Authorization: Coordinating with a Third-Party Assessment Organization (3PAO) to complete the formal assessment and achieve your certification.

What are the FedRAMP Requirements?

FedRAMP requirements are based on the National Institute of Standards and Technology (NIST) Special Publication 800-53. To meet these requirements, organizations must develop comprehensive documentation and implement strict technical controls.

Key deliverables include:

CMMC vs. FedRAMP: What’s the Difference?

If your organization is navigating the federal compliance landscape, you’ve likely heard of CMMC (Cybersecurity Maturity Model Certification) alongside FedRAMP. While both frameworks are rooted in NIST standards and share the goal of protecting government data, they apply to very different types of businesses:  

The two frameworks collide when a defense contractor uses a cloud service to store or process CUI. Under CMMC mandates, that contractor can only use a cloud service if the CSP is either fully FedRAMP Moderate Certified or has achieved 100% FedRAMP Moderate Equivalency (which requires a rigorous 3PAO assessment of its own).  

In short: If you provide cloud services, you need FedRAMP. If you provide goods, services, or research to the DoD, you need CMMC.

Check out our complete guide on CMMC vs. FedRAMP here.

Understanding FedRAMP Levels (and New Naming Conventions)

FedRAMP categorizes cloud systems based on the potential impact of a security breach.

Important Update: If you haven't been following the latest FedRAMP updates, the terminology is shifting. To align with other industry frameworks and reduce market confusion, the term FedRAMP "Authorized" is changing to FedRAMP "Certified." Furthermore, the traditional impact levels are transitioning to a streamlined Class-based system.

Here is how the new naming conventions break down:

How Long Does FedRAMP Certification Take?

FedRAMP Timeline

The timeline to achieve FedRAMP certification varies significantly depending on your organization's current security posture, the complexity of your system, and the Class (A-D) you are pursuing. Generally, the entire process, from initial scoping to final certification, can take anywhere from 9 to 12+ months.

A note on existing frameworks: If you already hold a SOC 2 or ISO 27001 certification, you have a great foundation. There is notable overlap in governance and basic security policies. However, FedRAMP requires a much more rigorous, technical implementation of controls. Having SOC 2 will speed up your gap analysis, but expect to invest significant engineering time to meet FedRAMP’s exacting architectural and technical standards.

How Does FedRAMP Pricing Work?

Achieving FedRAMP certification is a strategic investment. Costs are typically broken down into three buckets:

While the upfront cost is higher than commercial certifications, the ROI is substantial. A FedRAMP certification essentially unlocks the entire federal marketplace for your sales team.

What's Changing: FedRAMP 20x

As the cyber landscape evolves, so does FedRAMP. The upcoming "FedRAMP 20x" updates focus on modernizing the framework, improving automation, and accelerating the authorization timeline.

Here is what the FedRAMP 20x modernization means for cloud providers today:

A Shift to "FedRAMP Validated”

While legacy authorizations are shifting to the "FedRAMP Certified" label, 20x introduces the new FedRAMP Validated designation. This proves to agencies that your security isn't just a point-in-time audit, but a continuously monitored and automatically enforced reality.  

No Agency Sponsor Required

Traditionally, CSPs had to secure a federal agency sponsor before beginning the authorization process, a massive hurdle. FedRAMP 20x opens a direct-to-PMO authorization path, removing the sponsor bottleneck.  

Automation Replaces Prose

Instead of writing hundreds of pages explaining your security controls, 20x focuses on machine-readable data and automated continuous monitoring feeds. If you already have a strong commercial security framework in place, you can inherit many of those policies to reduce redundant documentation.  

Unprecedented Speed to Market

By removing the red tape and relying on automated validation, the 20x initiative has slashed approval times during its pilot phases. What once took well over a year is actively being streamlined down to a matter of months or even weeks.  These changes aim to get secure, commercial cloud technologies into the hands of federal agencies faster than ever. However, making the leap to a fully automated, machine-readable compliance posture requires serious technical maturity. 

What This Means for Your Strategy

For cloud service providers, these changes mean that getting FedRAMP Certified is becoming a more structured, logical process, but the technical bar remains as high as ever.

Your strategy should focus on proactive preparation. Don't wait for a federal agency sponsor to ask for your SSP to start building it. Begin your scoping and gap assessment now. Determine whether your target market requires Class B, C, or D certification, and build a roadmap to close those technical gaps.

Most importantly, don't do it alone. Navigating the transition from commercial security to federal compliance requires specialized expertise.

Ready to Speak to a FedRAMP Consultant?

At Rhymetec, we deliver the clarity, documentation, and expertise needed for successful certification. With a decade of trusted delivery and a 100% in-house team (never outsourced), we help you every step of the way, making an otherwise complex process clear, structured, and achievable.

From gap assessment and policy development to control implementation and 3PAO audit coordination, we simplify the journey so you can focus on unlocking new growth.

Contact us today to speak with one of our compliance experts.

The federal government spends more than $100 billion annually on IT services, much of it through contracts with private companies. That level of investment brings strict cybersecurity expectations, especially for contractors that handle government data. 

Two frameworks frequently encountered in this space are the Cybersecurity Maturity Model Certification (CMMC) and the Federal Risk and Authorization Management Program (FedRAMP). Both programs share the same goal of protecting sensitive information. However, they serve slightly different purposes and apply to different types of vendors. 

CMMC is designed for companies working with the Department of Defense, in particular for those that handle Controlled Unclassified Information (CUI). Over 100,000 companies are part of the Defense Industrial Base. Any of them that handle CUI will eventually need to meet CMMC Level 2 or 3. 

Meanwhile, FedRAMP applies to cloud service providers working with civilian federal agencies. If you are a defense contractor, a SaaS provider, or if your organization supports both civilian and DoD programs, it's important to understand how CMMC and FedRAMP compare.

This article outlines the main differences between CMMC and FedRAMP, including which types of organizations they apply to, the requirements of each framework, and how to handle certification.

CMMC vs. FedRAMP

Who Needs CMMC and Who Needs FedRAMP?

CMMC and FedRAMP apply to different groups of contractors and vendors based on two factors: 

  1. The agencies they serve, and
  2. The type of data they handle. 

In short, if you're in the DoD supply chain, you may need to meet CMMC. If you're a cloud provider for civilian agencies, you may need FedRAMP authorization. Some organizations may need to pursue both if they serve both sides of the government in these capacities.

Below is a non-exhaustive list of a few common types of companies to which CMMC would apply. Remember that CMMC applies to companies that do business with the Department of Defense (DoD) and process, store, or transmit Controlled Unclassified Information (CUI) or Federal Contract Information (FCI): 

Basically, if a company touches DoD contract information in any way (and in particular if it involves CUI), it will most likely fall under CMMC. 

FedRAMP, on the other hand, applies to cloud service providers that want to sell their platforms or applications to civilian federal agencies (non-DoD). The types of companies this would include are:

For more information on what you will need to plan for to meet CMMC requirements specifically - and depending on which level of CMMC you need - check out our CMMC Level 1 Checklist and our CMMC Level 2 Checklist.

Security Requirements Compared

While CMMC and FedRAMP indeed share some overlap given their common goal to protect sensitive government data, they are built on different baseline requirements, and their approaches to security controls differ.

CMMC is based on the NIST SP 800-171 framework. It requires organizations to implement 110 security controls across 14 control families if they handle CUI and need to meet Level 2 certification. For organizations handling only FCI (Federal Contract Information), Level 1 requires 15 controls focused on basic security hygiene. CMMC's overall requirements are structured around the following security considerations:

Additionally, organizations must also produce documentation, including System Security Plans (SSPs) and Plans of Action and Milestones (POA&Ms), and be ready for assessment by a third-party assessment organization (C3PAO) at Level 2 or 3. Lastly, it's important to note that CMMC 2.0 is not a point-in-time audit. Contractors are required to maintain compliance continuously. For Levels 2 and 3, assessment will lapse upon failure to annually affirm, according to the DoD's CMMC Guidance.

CMMC vs FedRAMP Assessments

FedRAMP, by contrast, is based largely on NIST SP 800-53 controls, which are a bit more complex in scope. A Moderate FedRAMP authorization requires over 300 controls across a wide range of domains, including:

FedRAMP places more emphasis on supply chain risk management, cloud architecture documentation, and the remediation of vulnerabilities. Cloud service providers must show that they have a set of documents to pass the Joint Authorization Board or agency review. 

Documentation and Assessment Differences To Be Aware Of: CMMC vs. FedRAMP

The goal of documentation for CMMC (at Level 2) is to show that your organization meets the 110 controls from NIST SP 800-171. This includes documentation of:

  1. How controls are being implemented, and the plan for how they will be maintained. This documentation is your System Security Plan (SSP).
  2. A Plan of Action and Milestones (POA&M) - A list of gaps and a plan for remediation, with specific steps. 
  3. A list of policies and procedures, showing how your organization covers access control, incident response, configuration management, and other security controls. 
  4. Evidence of implementation (such as user logs, training records, configuration screenshots, etc) also must be included in your documentation. 

Finally, assessment is conducted by a C3PAO (Certified Third-Party Assessment Organization) for Level 2. Self-assessment is allowed at Level 1 (and in some cases, for Level 2), but must still be documented in SPRS (Supplier Performance Risk System) and affirmed by a senior official. 

*It's important to note that if you need CMMC Level 3, you will still need C3PAO affirmation completed on an annual basis, according to the DoD's updated overview of CMMC. For CMMC Level 3, the ongoing C3PAO assessments are in addition to undergoing an assessment every 3 years by the Defense Contract Management Agency's Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). 

FedRAMP documentation, meanwhile, is part of a full authorization package submitted to either a sponsoring agency or the Joint Authorization Board. Required documents include: 

  1. System Security Plan (SSP) - this can often reach over 600 pages for Moderate-level systems!
  2. A Privacy Impact Assessment that identifies how personal data is being collected, used, and protected.
  3. A Continuous Monitoring Plan detailing how your organization will monitor system changes, incidents, and vulnerabilities.
  4. An Incident Response Plan, showing how incidents will be reported and handled.
  5. Documentation showing how system changes are approved and tracked (also known as a Configuration Management Plan). 

Assessment is carried out by a third-party assessment organization that has been recognized by the FedRAMP PMO (Program Management Office). FedRAMP requires ongoing authorization maintenance, which takes the form of monthly vulnerability scans, incident reporting, and annual reassessments. 

How Certification Works: CMMC vs. FedRAMP

CMMC 2.0 certification is tied to a company's eligibility for Department of Defense contracts. Depending on the sensitivity of the data involved, contractors must meet either Level 1 (self-assessed) Level 2 (typically third-party assessed) requirements, or Level 3 (third-party assessed). As discussed in greater detail in the previous sections, the process entails the following steps:

The first step is to conduct an internal NIST 800-171 gap assessment to compare where you are versus where you need to be. The next step is to document your System Security Plan and Plan of Action and Milestones, followed by finally engaging a certified third-party assessment organization (for Level 2 and 3). 

There is no central approval body, and certification is granted per contract, with the assessment scope being based on the environment that contains CUI. 

FedRAMP follows a centralized authorization process managed by the FedRAMP Program Management Office. There are two paths:

  1. Agency Authorization. For this option, a single agency sponsors the cloud service provider and reviews the authorization package. 
  2. Joint Authorization Board. Authorization via a Joint Authorization Board (which comprises the DHS, GSA, and the DoD) involves a higher bar of scrutiny. 

For the FedRAMP process, your organization will work with a Third-Party Assessment Organization to complete your Security Assessment Plan and Security Assessment Report. You'll then need to submit a full authorization package through FedRAMP's secure repository, and finally, undergo ongoing monitoring after approval.

Can You Be Compliant With Both?

The short answer is yes.

If your organization provides cloud-based services to civilian agencies and works with the Department of Defense, you likely need to comply with both FedRAMP and CMMC. For example, a SaaS company that supports DoD contracts involving CUI will need CMMC Level 2, and if the same product is then sold to a civilian agency (like the Department of Energy), they will also need FedRAMP authorization. 

CMMC and FedRAMP share foundational requirements from NIST standards. But it's not a direct map on - meeting FedRAMP Moderate, for instance, doesn't automatically mean you meet CMMC Level 2. The good news is it absolutely does reduce duplication in areas such as access control, system monitoring, and incident response. 

If you do need both CMMC and FedRAMP, figuring out early on how to align both compliance efforts can reduce cost and headaches down the road. This is a common use case for working with a consultant to manage both tracks. A consultant has the experience implementing these requirements across a large spectrum of different types of organizations, and can help ensure efficient implementation.

When To Bring In A Consultant Or MSSP

A recent report by the U.S. Government Accountability Office shows that many small businesses in the defense industry lack the internal resources to implement NIST 800-171 without outside help. This illustrates a growing need for CMMC consultants and MSSPs. 

In the report, many smaller businesses in particular expressed concerns about the costs and resources required for CMMC implementation. This is where outsourcing the process can be transformative. Outsourcing is a fraction of the investment that building out an in-house team to carry out the implementation process would be. 

The fact is that organizations often wait too long to bring in help, and this can lead to missed deadlines and unnecessary rework. If you're pursuing CMMC, FedRAMP, or both, bringing in a consultant early can reduce risk and cost. 

It can be a good idea to bring in a consultant or MSSP if you don't have internal staff with experience in NIST 800-171 or 800-53 implementation, if you're unsure how to scope your CUI, if you're being asked to respond to a security questionnaire and aren't confident in your answers, or if you need to align your environment for both frameworks. 

A consultant will perform a gap analysis, build a compliance roadmap, draft documentation for you, implement technical controls, and fully prepare your team for assessment. For small and mid-sized organizations, especially those with aggressive go-to-market timelines, outsourcing to a qualified team helps avoid delays and prevents compliance from blocking growth.

About Rhymetec

Our mission is to make cutting-edge cybersecurity available to SaaS companies and startups. We’ve worked with hundreds of companies to provide practical security solutions tailored to their needs, enabling them to be secure and compliant while balancing security with budget. We enable our clients to outsource the complexity of security and focus on what really matters – their business. Contact us today to get started.