In 2024, the public sector faced a number of data breaches, highlighting the vulnerability of government agencies and public institutions in the face of evolving cyber
The Federal Risk and Authorization Management Program (FedRAMP) is a U.S. government program designed to standardize and streamline the assessment, authorization and continuous monitoring of cloud computing services for federal agencies. It establishes a consistent set of security requirements for Cloud Service Providers (CSPs) to ensure their products meet the rigorous security and privacy needs of the federal government.
The difference between being FedRAMP Authorized and FedRAMP equivalent is that a FedRAMP-Authorized product has been officially recognized as a secure and compliant cloud solution approved for federal government use and is listed in the official FedRAMP Marketplace. In contrast, a FedRAMP-equivalent product is a self-attestation to a similar level of security effort and intent, but the product is not listed in the official FedRAMP Marketplace.
What does “FedRAMP equivalency” mean?
CSPs who claim to have achieved FedRAMP equivalency are stating that their product meets security standards comparable to FedRAMP, but the CSP has not formally completed the rigorous FedRAMP Authorization process. This term might be used by non-U.S. organizations, state governments or private entities implementing controls based on FedRAMP guidelines. Often, but not always, CSPs use FedRAMP equivalency to indicate FedRAMP compliance readiness or an intent to pursue full FedRAMP Authorization.
The key characteristics of FedRAMP equivalency are as follows:
- The CSP self-attests that their product either aligns with FedRAMP security controls or uses them as a benchmark.
- The CSP’s product may or may not have been formally assessed or granted an Authorization to Operate (ATO) by a federal agency or the Joint Authorization Board (JAB).
- The CSP’s product is not listed on the official FedRAMP Marketplace.
What does FedRAMP Authorized mean?
CSPs selling FedRAMP-Authorized products have completed the FedRAMP authorization process, including rigorous security assessments conducted by a Third Party Assessment Organization (3PAO), and the product has been granted an ATO by a federal agency or the JAB.
The key characteristics of FedRAMP authorization are as follows:
- The CSP’s product has undergone a very detailed security review and testing process by a 3PAO and must undergo a reauthorization audit annually.
- The CSP’s product has been granted an ATO by a federal agency or the JAB.
- The CSP’s product is listed on the official FedRAMP Marketplace.
Key differences between FedRAMP equivalent and FedRAMP Authorized
The following table summarizes the primary differences between FedRAMP equivalency and FedRAMP authorization.
|
FedRAMP Authorized | FedRAMP Equivalent |
---|---|---|
Definition | A cloud product that has undergone the full FedRAMP security assessment process and received an official Authority to Operate (ATO) or Provisional Authority to Operate (P-ATO). | A cloud product that claims to be aligned with FedRAMP security controls but has not completed the formal FedRAMP authorization process. |
Assessment Process | Requires a formal review by a FedRAMP-approved 3PAO and approval from a federal agency or the JAB. | Often involves internal assessments or informal audits aligned with FedRAMP standards, which may or may not have been done with oversight by a 3PAO or federal entity. |
Security Standards | Fully compliant with FedRAMP’s standardized controls, derived from NIST SP 800-53. | Aligns with FedRAMP security controls but may not fully meet them. |
Government Recognition | Listed on the FedRAMP Marketplace and officially recognized by federal agencies. | Not listed on the FedRAMP Marketplace and may not be recognized by federal agencies. |
Verification | Includes comprehensive documentation, audits and ongoing monitoring validated by the U.S. government. | May or may not include partial documentation and assessments. |
Continuous Monitoring | Requires continuous monitoring, with regular reporting and updates to maintain authorization. | Continuous monitoring may be implemented but not necessarily aligned with FedRAMP’s formal requirements. |
Use Cases | Can be used by U.S. federal agencies procuring cloud services. Suitable for systems processing sensitive but unclassified (Moderate) or highly sensitive (High) data. | May be used for state, local or private sector applications where full FedRAMP authorization is not mandatory. May not be sufficient for direct federal use and cannot be used for highly sensitive (High) data. |
Reusability Across Agencies | Can be reused across multiple federal agencies without having to examine the CSP’s entire Body of Evidence (BoE). This significantly reduces the time and cost of evaluating and onboarding the product. | No reusability. Each agency or organization may need to conduct its own security assessment, including a review of the CSP’s entire BoE, including their System Security Plan (SSP), Security Assessment Plan (SAP) and all attachments. This duplicates effort and significantly increases the time and cost of evaluating and onboarding the product. |
The risks of working with a “FedRAMP-equivalent” provider over a FedRAMP-Authorized provider
Choosing to work with a FedRAMP-equivalent CSP instead of a FedRAMP-Authorized CSP carries certain risks due to the absence of formal validation and government recognition of the provider’s security measures. Additional risks of working with a “FedRAMP-equivalent” CSP include possible security gaps and inconsistent implementation of security controls. FedRAMP authorization includes 325+ controls and continuous monitoring to ensure a very high standard of security. Equivalent providers may implement fewer controls or lack robust monitoring processes. Furthermore, because there is no standardized certification process for FedRAMP equivalency, the level of compliance can vary significantly between CSPs.
Due to these risks, FedRAMP-equivalent products are most appropriate for non-federal organizations, such as private companies or state and local governments, that need alignment with high-security standards without the cost of a FedRAMP-Authorized product. For example, a private-sector healthcare organization may use a FedRAMP-equivalent system to help ensure data security for compliance with HIPAA.
The bottom line
Working with a FedRAMP-equivalent provider over a FedRAMP-Authorized provider exposes organizations to risks such as security gaps, non-compliance and increased vulnerability to cyber attacks. While FedRAMP-equivalent CSPs may demonstrate good faith in aligning with security standards, only FedRAMP-Authorized CSPs undergo the formal validation and continuous monitoring required to fully mitigate these risks.
Further, evaluating a FedRAMP-equivalent provider is a time-consuming and expensive process that involves examining the provider’s entire BoE, which typically includes hundreds if not thousands of pages of documentation. Conversely, choosing a FedRAMP-Authorized provider means that a 3PAO has already examined the provider’s BoE, tested its controls and confirmed that the provider’s product meets FedRAMP standards. Agencies can verify this simply by checking the CSP’s listing in the official FedRAMP Marketplace.
For federal use, working with a FedRAMP-Authorized provider, such as Keeper, is essential to ensure robust security and compliance.