SaaS companies with a federal sponsor in sight
An agency champion wants your product and is willing to sponsor it. You need to show up with a credible boundary, a realistic baseline and a package that won’t stall the agency’s review.
A federal agency wants to buy your cloud service, and the honest answer to “are you FedRAMP authorized?” is not yet. Readiness tells you which baseline you’re facing, draws an authorization boundary you can defend and builds the package and controls a 3PAO will assess, so your first formal assessment isn’t also your first gap analysis.
FedRAMP is the government-wide program for authorizing cloud services that federal agencies use, codified in law by the FedRAMP Authorization Act. It is built on NIST SP 800-53 Rev 5, organized into Low, Moderate and High baselines plus LI-SaaS for low-impact SaaS, with FedRAMP-specific parameters and requirements layered on top. Your baseline follows from a FIPS 199 categorization of the federal data your service will hold, and most commercial SaaS sold to agencies lands at Moderate.
The established route is agency authorization. An agency sponsors your service, a FedRAMP-recognized Third Party Assessment Organization (3PAO) tests it against the baseline and documents results in a Security Assessment Report, and the agency issues an Authority to Operate. After that, continuous monitoring keeps the authorization alive. Some providers first seek a FedRAMP Ready designation, which requires a Readiness Assessment Report (RAR) from a 3PAO. Our work comes before that RAR — we don’t produce it.
FedRAMP is also changing. FedRAMP 20x is the program’s modernization effort, moving toward automated, machine-readable validation and less narrative documentation; it is being introduced through pilots and its details are still settling, while the Rev 5 path remains in use. Either way, an assessor will examine the same fundamentals — boundary, cryptography, identity, vulnerability management, configuration and incident response — so teams come to readiness to get those right once, whichever path their sponsor and the program support.
An agency champion wants your product and is willing to sponsor it. You need to show up with a credible boundary, a realistic baseline and a package that won’t stall the agency’s review.
You’re deciding whether FedRAMP is worth it and at which baseline. You need a clear-eyed view of the gap between your current environment and what authorization demands before you commit.
Your commercial program is mature, but FedRAMP asks for more: FIPS-validated cryptography, documented parameters for hundreds of controls and continuous monitoring deliverables. You need to know what carries over and what doesn’t.
New features, new regions or new underlying services can change your boundary and trigger a significant change request. You need to understand the impact before your agency and your 3PAO do.
A federal agency, which grants the Authority to Operate after a FedRAMP-recognized 3PAO assesses your service
An agency ATO and a FedRAMP Authorized listing on the FedRAMP Marketplace; a 3PAO’s Readiness Assessment Report supports a FedRAMP Ready designation
Readiness happens before the 3PAO arrives: before the Readiness Assessment Report, the Security Assessment Plan and the Security Assessment Report. CyberlySecure produces none of those — your 3PAO does, independently.
A written FIPS 199 categorization, the baseline it leads to and a reasoned position on what sits inside and outside your authorization boundary.
Diagrams in the form the program expects, showing components, federal data flows, interconnections and leveraged services.
Each control and enhancement in your baseline marked implemented, partially implemented, planned or inherited, with the evidence and the work needed to close every gap.
An SSP that describes how your system implements each control, plus the attachments that travel with it — so the package your 3PAO receives tells the truth about your service.
Control family policies and procedures, a configuration management plan, an incident response plan and an information system contingency plan built around your actual operations.
A clear split of which controls you meet, which you inherit and which your agency customers must meet themselves.
Open findings recorded in the structure FedRAMP uses, prioritized by risk, with owners and milestones.
How you will keep scanning, inventory, POA&M updates and significant change requests current once authorized, so the ATO survives its first year and every one after.
A final check of your package, evidence and people against what a 3PAO examines, so the formal assessment confirms work you’ve finished rather than discovering work you haven’t.
Better found now, by people on your side, than by your assessor.
An authorization boundary that leaves out corporate tools, CI/CD pipelines or support systems that can reach federal data
Encryption with strong algorithms implemented through modules that aren’t FIPS 140 validated
Third-party services inside the boundary that hold no FedRAMP authorization
Vulnerability scanning that is unauthenticated, misses part of the inventory or isn’t tied to remediation deadlines
An SSP that restates control text instead of describing how your system actually implements each control
An asset inventory that doesn’t match what the scanners and cloud consoles see
No evidence of contingency plan or incident response testing
No customer responsibility matrix, leaving agencies unsure which controls they own
Control CA-8 requires penetration testing at Moderate and High, and FedRAMP’s penetration test guidance includes tenant-to-tenant and tenant-to-management attack vectors. Testing early shows what a 3PAO’s test is likely to find.
What the test coversThe customer-facing application is usually the largest part of the attack surface inside the boundary, and the place agency reviewers look hardest.
What the test coversAPIs that agencies integrate with cross the boundary by design; testing them checks authentication, authorization and tenant isolation where federal data moves.
What the test coversFedRAMP’s guidance includes an attack vector from outside the system to the CSP target system; an external test covers the same ground before the 3PAO does.
What the test coversMost FedRAMP services run on an authorized IaaS. A configuration review checks the settings you own against the baseline controls you claim to meet.
What the test coversThe guidance also includes an external-to-corporate vector, which reaches the people who administer your service; a phishing exercise measures that exposure.
What the test coversIf your service offers a mobile app, the guidance includes a mobile-application-to-CSP vector that an assessor will expect to see addressed.
What the test coversNo. FedRAMP Ready requires a Readiness Assessment Report from a 3PAO, reviewed by the FedRAMP program, and authorization comes from an agency after a 3PAO assessment. CyberlySecure is not a 3PAO. Our work comes before the RAR and before the formal assessment, which keeps the firm that prepares you separate from the firm that evaluates you.
For the established agency authorization path, yes — an agency issues the ATO, so one has to want your service. The program has been changing how authorizations work, including through FedRAMP 20x pilots, so check current FedRAMP guidance for the path open to your service. Readiness work is useful on every path, because every path assesses the same security fundamentals.
It follows from the FIPS 199 impact of the federal data you’ll hold. Low-impact SaaS that holds little more than login data may fit LI-SaaS; most services handling agency business data are Moderate; services supporting law enforcement, emergency services, financial systems or health data with severe impact may be High. Your sponsoring agency has a say, so readiness documents the categorization in a form you can discuss with them.
FedRAMP 20x is the program’s effort to modernize authorization around automated, machine-readable validation instead of lengthy narrative documents. It is being rolled out through pilots and continues to evolve, while the Rev 5 process remains in use. Waiting rarely helps: the controls you need — boundary, FIPS-validated encryption, identity, scanning, logging, incident response — are the same either way, and they take real engineering to put in place.
The culture and many of the processes carry over: access reviews, change management, risk assessment, vendor management. What usually doesn’t: FIPS-validated cryptography, FedRAMP-defined parameters, a formally defined authorization boundary, authenticated scanning of every asset, and the depth of SSP documentation. Readiness maps your existing evidence to the baseline so you reuse what you can and only build what’s missing.
Often. DoD cloud authorizations build on FedRAMP through the DISA Cloud Computing Security Requirements Guide, CMMC requires FedRAMP Moderate or equivalent for cloud services that hold CUI, GovRAMP offers a path that recognizes FedRAMP work, and Texas DIR can recognize FedRAMP for TX-RAMP. One well-built package can open several doors.
One conversation with someone who does this work. You leave knowing where you likely stand and what readiness would involve for you.
Not sure where to start? One of our testers reviews your internet-facing footprint and sends you a short summary of what an attacker would see — free. Nothing you don’t own is ever touched, and there’s no sales sequence.
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