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FedRAMP Guide (2026): 20x Certification Classes, Rev5 Sunset and How to Get Certified

FedRAMP is the US government's programme for assessing the security of cloud services used by federal agencies. It was established in law by the FedRAMP Authorization Act in December 2022 and redirected by OMB Memorandum M-24-15 in July 2024 ([FedRAMP](https://www.fedramp.gov/20x/)). In 2026 it changed substantially: - **New terminology.** In May 2026, "FedRAMP Authorization" became **FedRAMP Certification**, and impact levels became **Certification Classes A–D** ([FedRAMP](https://www.fedramp.gov/changelog/)). - **Consolidated Rules.** The Consolidated Rules for 2026 (CR26) were released on 24 June 2026 ([FedRAMP](https://www.fedramp.gov/changelog/)). They apply to all providers by 31 December 2026 and remain valid until 31 December 2028 ([FedRAMP NTC-0008](https://www.fedramp.gov/notices/0008)). - **20x pipelines.** FedRAMP 20x uses automated Key Security Indicators in place of point-in-time paperwork. Its Class A pipeline opened on 3 August 2026, and Classes B and C opened on 31 August 2026 ([FedRAMP](https://www.fedramp.gov/2026-07-30-fedramp-certification-paths-are-heating-up)). - **Rev5 cutoff.** FedRAMP will stop processing new Rev5 Certification applications on **11 June 2027** ([FedRAMP](https://www.fedramp.gov/2026-10-08-from-foundation-to-implementation)).

By AssureCore Compliance Team · Last reviewed

Who it applies to

FedRAMP applies to cloud service providers (CSPs) whose services federal agencies use. It also involves the agencies that authorise those services and the recognised independent assessors (3PAOs).

The Marketplace lists certified services, authorising agencies and recognised assessors. As of 23 October 2026 it showed 547 certified services, 33 of them certified under 20x (FedRAMP).

A FedRAMP Certification counts as "FedRAMP authorized" for statutory and regulatory purposes. However, each agency still makes its own risk decision and issues its own ATO, and it may use a package at a different security category than the Certification class (FedRAMP NTC-0004).

Key requirements

Certification Classes

Mapping to the historical baselines (FedRAMP NTC-0004; FedRAMP NTC-0008):

  • Class A: a new, time-limited pilot or entry tier.
  • Class B: the former Low and LI-SaaS baselines.
  • Class C: the former Moderate baseline.
  • Class D: the former High baseline.

FedRAMP says a class reflects "the depth and complexity of the information provided," not the overall security of a system (FedRAMP NTC-0004).

FedRAMP 20x

20x is built on five principles (FedRAMP):

  • transparency
  • flexibility
  • accountability
  • accuracy
  • automatic validation

Providers define their security goals and demonstrate them through Key Security Indicators that are validated continuously rather than "staged for a point-in-time audit." Certification types (FedRAMP; FedRAMP):

  • Class A: for mature security programmes entering the market. You can submit with a complete Readiness Assessment Report or a SOC 2 Type II. Once a federal customer uses the service, you have 12 months to begin moving to Class B or higher.
  • Class B: light-use or small-scale services.
  • Class C: common enterprise services used across an entire agency, or important government services.
  • Class D: being developed in Phase 4. A pilot is planned, with RFC-0036 published 14–15 October 2026 (FedRAMP).

Rev5

Rev5 is the legacy path built on control baselines. In March 2026, FedRAMP opened RFCs to update baselines across the control families (AC, AU, CM, CP, IA, IR, RA, SC, SI, SR and others), followed by an initial outcome notice in June (FedRAMP). Rev5 providers must also adopt machine-readable packages (RFC-0024) (FedRAMP).

Continuous obligations

The Marketplace now shows the following for each service (FedRAMP):

  • the lifecycle phase (Initial Implementation or Ongoing Certification)
  • a "FedRAMP Certified (In Remediation)" status
  • a Corrective Action Plan indicator
  • a Certification History event log

FedRAMP also runs quarterly Security Inbox tests and issues notices in response to CISA directives, such as BOD 26-04 (FedRAMP).

Certification process and timeline

The 20x route has four steps:

  1. Initial Implementation listing on the Marketplace. FedRAMP added 71 services in FY26 (FedRAMP).
  2. Class A submission, using a RAR or SOC 2 Type II (FedRAMP).
  3. Class B or C submission with Key Security Indicator evidence (FedRAMP).
  4. Ongoing Certification through continuous validation (FedRAMP).

How 20x developed:

  • Phase 1 (Low pilot): ran from April to September 2025 and received 26 complete packages.
  • Phase 2 (Moderate pilot): ran from November 2025 to March 2026, with the first pilot authorizations on 6 March 2026.

FedRAMP's lessons learned were that Key Security Indicators can show security posture in near real time, and that the approach adapts readily to higher levels of security (FedRAMP).

FedRAMP aims to "deliver initial assessment decisions within 30 days of application" (FedRAMP).

Rev5 routes:

  • the traditional agency sponsor path
  • limited, temporary Rev5 Program Certification pipelines (Lost Sponsor and Ready Conversion), opened on 10 August 2026. FedRAMP does not plan to expand eligibility (FedRAMP; FedRAMP).

FedRAMP Ready was retired at the end of July 2026 and became "Legacy FedRAMP Ready" (FedRAMP).

FY26 by the numbers (FedRAMP):

  • 92 new Certifications (66 Rev5 and 26 20x)
  • 538 certified offerings at year end
  • 760 new agency ATOs or ATUs

Costs

FedRAMP doesn't publish assessment costs. It dropped a proposal to collect them, noting that costs vary widely with scope and complexity (FedRAMP NTC-0002).

Penalties

FedRAMP doesn't impose fines. The risks are commercial:

  • losing federal eligibility
  • a Marketplace status of "In Remediation"
  • a visible Corrective Action Plan (FedRAMP)

Agencies also make their own ATO decisions (FedRAMP NTC-0004).

Mapping to related frameworks

  • SOC 2 Type II: can support a Class A submission (FedRAMP).
  • NIST 800-53 and NIST CSF: Rev5 baselines are organised by control family (FedRAMP).
  • CMMC and NIST 800-171: relevant to defence contractors using cloud services.
  • ISO 27001 and CSA STAR: commercial evidence that 20x aims to reuse instead of mandating "a specific government-focused approach" (FedRAMP).

Readiness checklist

  1. Choose a target class (A, B or C) based on how agencies will use your service.
  2. If you already have one, use a SOC 2 Type II report or RAR to pursue Class A.
  3. Define security goals and automate Key Security Indicator validation.
  4. Produce machine-readable packages that follow the CR26 JSON schemas (FedRAMP).
  5. Engage a FedRAMP-recognised assessor.
  6. Rev5 providers: plan migration before the 11 June 2027 cutoff.
  7. Monitor RFCs, public notices and the Security Inbox requirements.

Common pitfalls

  • Still using Low, Moderate and High labels in sales and contracts.
  • Starting a new Rev5 effort without a guaranteed sponsor. FedRAMP advises pivoting to 20x "immediately" (FedRAMP).
  • Treating Certification as an agency ATO.
  • Missing Class A's 12-month transition clock once you have a federal customer.
  • Manual evidence that can't support continuous validation.

How AssureCore helps

  • Cross-framework Mapping reuses SOC 2 and ISO 27001 controls for FedRAMP.
  • The Controls Register and Evidence Management, with expiry alerts, keep evidence current.
  • The Risk Register and action plans track corrective actions.
  • Audit Reports (PDF/CSV) support assessor review.

Frequently asked questions

What is the difference between FedRAMP Certification and authorization?

Since May 2026, FedRAMP uses "Certification" for its own decision. Agencies still issue their own Authorizations to Operate.

What replaced FedRAMP Low, Moderate and High?

Certification Classes. Class B covers Low and LI-SaaS, Class C covers Moderate, Class D covers High, and Class A is a new entry tier.

Can I use SOC 2 for FedRAMP?

Yes. A complete SOC 2 Type II report or Readiness Assessment Report can support a 20x Class A submission.

When does FedRAMP Rev5 end?

FedRAMP will stop processing new Rev5 Certification applications on 11 June 2027. Transition paths for existing offerings are expected by the end of FY27.

Is FedRAMP 20x available for High?

Not yet. Class D is in pilot development, with RFC-0036 published in October 2026.

How long does FedRAMP take?

FedRAMP aims to deliver initial assessment decisions within 30 days of application. Overall time depends on your readiness.

Official references

Supporting evidence and assessment preparation

Evidence examples

Keep approved policies, scope decisions, risk records and operating evidence linked to accountable owners. Record the source, period covered, review and exceptions.

Assessment preparation

Review the applicable requirements and evidence with their owners. Reconcile gaps, findings and action plans, and prepare a clear scope narrative and evidence index.

Common failure points

Avoid treating a framework as a one-time checklist, collecting evidence without context, or leaving decisions and corrective actions undocumented.

Explore workspace guidance or browse other framework guides.

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