FedRAMP's Latest RFCs: The Top 3 Updates Cloud Service Providers Should Know

FedRAMP is signaling a significant shift in how cloud service providers (CSPs) can enter and navigate the federal marketplace. Recent Requests for Comments (RFCs), while still in draft form, provide a clear preview of the program’s direction, which prioritizes modernization, automation, and faster pathways to authorization.

Matt Hungate, Federal Practice Leader at Schellman, explains three key takeaways that every CSP operating in or targeting the FedRAMP market should know.

1. FedRAMP Is Creating a Faster On-Ramp to the Federal Market

One of the most notable signals from the recent RFCs is FedRAMP’s effort to reduce friction for cloud providers already operating under mature commercial security frameworks. A proposed pilot would allow CSPs to reuse elements of existing frameworks, such as SOC 2 or ISO/IEC 27001, within the FedRAMP authorization process.

While this does not mean full reciprocity or automatic authorization, it does offer a meaningful head start. Organizations that have already invested in robust commercial compliance programs may be able to leverage that work to accelerate their FedRAMP journey rather than starting from scratch. 

For cloud-native providers, this represents a more realistic and attainable entry point into the federal market.

2. Agency Sponsorship Is No Longer the Primary Bottleneck

Historically, one of the biggest challenges for CSPs pursuing FedRAMP authorization has been securing a sponsoring federal agency. Many providers have strong agency interest but struggle to obtain formal sponsorship, which can stall progress indefinitely.

FedRAMP is now addressing this issue directly. Under the evolving model, FedRAMP itself will take on a larger role in reviewing and issuing Rev. 5 authorization packages, without requiring agency sponsorship as the gating factor. Notably, FedRAMP has indicated it will issue Rev. 5 certifications through the end of 2026.

For organizations already planning for or aligned with Rev. 5 requirements, this change opens a more predictable and accessible path forward.

3. FedRAMP Modernization and Automation Are Central

The clear direction emphasizes that FedRAMP modernization is well underway. Automation, control reuse, and streamlined authorization processes are central to the program’s priorities and future state.

That said, this evolution should not be mistaken for reduced rigor as FedRAMP is not becoming “easier" to achieve. Instead, it is changing how compliance is demonstrated, reviewed, and maintained. CSPs that embrace automation, continuous monitoring, and reusable compliance artifacts will be better positioned to succeed under the new model.

Early adopters who align their security programs with this direction are likely to gain a competitive advantage as these changes take effect.

FedRAMP's Evolving Landscape

FedRAMP's recent RFCs make it clear that the program is evolving. Faster federal market access, reduced dependency on agency sponsorship, and a strong emphasis on automation are reshaping the authorization landscape.

Providers that begin adapting now, by aligning commercial frameworks, preparing for Rev. 5, and investing in automation, will be best positioned to move quickly as these changes are finalized.

For organizations navigating this transition, working with an experienced FedRAMP Third-Party Assessment Organization (3PAO) like Schellman can help translate these signals into a practical, executable strategy. Contact us today to learn more and discover additional FedRAMP insights in the following resources: 

• FedRAMP 20x: The Most Frequently Asked Questions
• FedRAMP 20x Low Baseline Pilot: Modernizing Federal Cloud Authorization
• FedRAMP 20x: What’s Changing and What It Means for Your Business