Federal Cloud Security

FedRAMP 20x, Visually: Classes, KSIs, Deadlines and Cost

Published November 6, 2026

By Kelvin O. Medina

Last checked November 6, 2026 against fedramp.gov (Consolidated Rules for 2026, notice NTC-0014, RFC-0033 and RFC-0036). We update this page when the rules change.

FedRAMP changed more in 2026 than in the decade before it. Low, Moderate and High are now Classes A to D. “Authorized” is now “certified.” And the new 20x path lets a cloud company get certified without an agency sponsor.

This guide explains the new rules in seven visuals, with every requirement linked to its source on fedramp.gov.

Already certified? Jump to the deadlines: new vulnerability rules apply from December 7, 2026.

FedRAMP 20x vs Rev5: 20x proves security with measurements, not documents

Rev5 is now the legacy path. You find an agency sponsor, describe every NIST SP 800-53 control in a System Security Plan, and an assessor checks it at a point in time. It suits services that run their own infrastructure.

20x is for cloud-native services built on FedRAMP-certified infrastructure. You prove Key Security Indicators (KSIs) with measurements your own tools produce, publish them as JSON, and FedRAMP certifies you directly. No sponsor needed.

Figure 1

Same goal, different machine

REV5 · LEGACY · AGENCY PATHAgency sponsorSystem Security Plan3PAO assessmentAgency review + ATOFedRAMP Certificationneeded before you startprose for every controlpoint in timesponsor decidesannual reassessment20X · MODERN · PROGRAM PATH (NO SPONSOR)Your cloud toolingAutomated validationsPackage as JSONIndependent assessmentProgram CertificationIAM, logs, config, CI/CDmeasure every KSIOverview + Decision Recordwithin 3 months (B, C)issued by FedRAMP directlyNever stops: validations keep running; package refreshed every 2 weeks (Class C) or monthly (Class B)
The core shift: Rev5 proves security with documents a person reviews once a year. 20x proves it with measurements a machine produces all year. Sources: fedramp.gov “Choose a Type”, CPO-CSX-CPM.

The new vocabulary in one table

You used to sayUnder the 2026 rules
FedRAMP AuthorizedFedRAMP Certified
Low / Moderate / HighClass B / Class C / Class D (plus a new entry-level Class A)
System Security Plan (SSP)Security Decision Record (SDR), human-readable + JSON
Agency sponsorProgram path (no sponsor) for 20x; Agency path remains for Rev5
FedRAMP ReadyLegacy since July 28, 2026; use 20x Class A instead
Monthly ConMon deliverablesOngoing Certification Report every 3 months + persistent validation

Source: Choose a Type · Certification Package Overview. Checked November 6, 2026.

Which FedRAMP class do you need? Usually the lowest one your customers accept

FedRAMP publishes its own decision workflow. Three questions get most companies to the right answer. Start with the first one: 20x isn’t available if you run your own infrastructure.

Figure 2

The FedRAMP class decision tree

Does your service run on its own infrastructure(your own datacenter or physical hosting)?Do you already hold a FedRAMP certificationfor this service?Do agency customers already requireFedRAMP for this service?Rev5The only option for self-hosted services.Usually needs an agency sponsor.Move up a classInvest in the class your agency customersneed and are willing to pay for.Lowest class that meets the requirementUsually B or C. FedRAMP advises against goingstraight to C or D without a contract.YESYESYESNO · built on FedRAMP-certified IaaS/PaaSNONOStart with 20x Class ARequires SOC 2 Type II, GovRAMP, or FedRAMP Rev5 (includingReady) completed in the last 12 months, plus 7 KSIs.ISO 27001 doesn’t qualify. No prerequisite? See section 10.Need Class D (the old High)?Today: Rev5 only.20x pilot: hold 20x Class C by Dec 1, 2026,apply Dec 1–4. Maximum 10 participants.
Read it top to bottom. Based on FedRAMP’s “Choose a Class” and “Choose a Type” pages, Class A prerequisite rule FRC-CLA-ASF, and RFC-0033 for the Class D pilot.

FedRAMP’s own advice, in short

  • No federal customer yet? Class A is “the simplest way to get FedRAMP Certified to obtain a customer.”
  • Customers already asking? Pick the lowest class that meets their requirement.
  • Thinking of C or D? Don’t go straight there unless an agency contract requires it.

Source: Choose a Class · 20x Class A rules · RFC-0033. Checked November 6, 2026.

FedRAMP 20x Classes A to D: your class sets how much you automate, not how secure you are

Your class sets how much you automate, how much you share and how fast you must react. It doesn’t rate how secure you are. Class C is highlighted because it’s the class most agencies will ask for.

RequirementClass AMarket entry · newClass BReplaces LowClass CReplaces ModerateClass DReplaces High
Built forMature commercial products with SOC 2 Type II entering the federal marketSmall-scale or light-use servicesCommon enterprise and important government servicesMission-critical services
Available as 20x?Yes, since Aug 3, 2026Yes, since Aug 31, 2026Yes, since Aug 31, 2026Rev5 today; 20x pilot proposed (RFC-0036)
Entry requirementSOC 2 Type II, GovRAMP or Rev5/Ready within 12 monthsFresh independent assessmentFresh independent assessment20x Class C held 6 months with no corrective action; hosted on Class C or D IaaS/PaaS Proposed
KSIs required741 (5 more optional)All 4646 + 10 new Proposed
Automated checks per KSINot requiredAt least 1 ShouldAt least 2 MustAt least 4 Proposed
KSI history at applicationOptional30-day + up to 1-year summary Should6 months minimum; daily data up to 1 year MustData every 4 hours, up to 1 year Proposed
Independent assessmentOptional at application; annual afterwardWithin 3 months before applyingWithin 3 months before applyingRev5 assessment today
Package refreshEvery 3 months ShouldEvery monthEvery 2 weeksEvery week
Quarterly review meetingMayShouldMustMust

PROPOSED = from RFC-0036; may change. Rules: FRC-CLA-ASF FRC-CLA-MFR FRC-CSX-VVK FRC-CSX-MOT SDR-CSX-KMT FRC-APP-FIA IVV-CSX-AIA CPO-CSX-CPM CCM-QTR-MTG

Class D: what RFC-0036 proposes

Class D (the old High) is Rev5 only today. RFC-0036 proposes the rules for a 20x Class D pilot. Expect a high bar:

  • Class C first. Hold 20x Class C for 6 months with no corrective action. Pilot applicants need Class C, but not the 6 months.
  • Certified hosting. Run on Class C or D certified infrastructure.
  • More automation. At least 4 automated checks per KSI, 10 new KSIs, and metrics every 4 hours.
  • Data by API. The whole machine-readable package served through an API.
  • Post-quantum status. Document where your encryption stands on post-quantum algorithms.

Pilot dates: apply December 1–4, 2026 (Class C already in hand, 10 places). Draft package due February 17, 2027; final package March 17, 2027.

Rules: FRC-CLD-PCD FRC-CLD-CCH SDR-CSX-KMT CDS-CSX-API CMU-CSO-PQS · Pilot: RFC-0033

Source: Class A and Class C certification rules · RFC-0036 (Class D, proposed). Checked November 6, 2026.

FedRAMP deadlines: the first hard date is December 7, 2026

The 20x pipelines are open. Three dates matter most from here:

  • December 7, 2026: new vulnerability rules become mandatory for every certified offering.
  • January 1, 2027: the 2026 rules become mandatory for everyone.
  • June 11, 2027: last day to apply for a new Rev5 certification.

Figure 3

The FedRAMP transition timeline

JulAugSepOctNovDecJan ’27FebMarAprMayJunJul 4New rules: optional early adoptionAug 3 · Class A opens20x Class A pipelineAug 31 · Classes B & C open20x Class B and C pipelinesJul 28 · FedRAMP Ready goes legacyNo new Ready submissionsAug 10 · Temporary Rev5 pipelinesReady Conversion, Lost SponsorDec 1–4 · Class D pilot windowMust already hold 20x Class CDec 7 · Vulnerability rules mandatoryVDR + VER for every certified offeringMar 7, 2027 · Grace endsNot following VDR/VER = revokedJan 1, 2027 · Rules mandatoryApplies to all stakeholdersJun 11, 2027Last day for new Rev5certification applicationsToday · Nov 6
Already open: everything left of the dashed line. Dates from fedramp.gov “Important Dates”, notice NTC-0014 (vulnerability rules) and RFC-0033 (Class D pilot).

Source: Important Dates · Notice NTC-0014 · RFC-0033. Checked November 6, 2026.

All 46 FedRAMP 20x KSIs: Class A needs 7, Class C needs all 46

A KSI is a security outcome you prove with live measurements instead of a written description. Each one maps back to NIST SP 800-53 controls. In the chart, each square is one KSI.

Figure 4

46 KSIs, 10 themes, and which class needs which

Cybersecurity EducationChange ManagementCloud Native ArchitectureIdentity & Access ManagementIncident ResponseMonitoring, Logging & AuditingPolicy & InventoryRecovery PlanningSupply Chain RiskService Configuration1486355428KSI-CED-RAT Reviewing All Training (Class A)KSI-CMT-LMC Logging Changes (Class A)KSI-CMT-RMV Redeploying vs ModifyingKSI-CMT-RVP Reviewing Change ProceduresKSI-CMT-VTD Validating Throughout DeploymentKSI-CNA-DFP Defining Functionality and PrivilegesKSI-CNA-EIS Enforcing Intended State (optional at B)KSI-CNA-IBP Implementing Best PracticesKSI-CNA-MAT Minimizing Attack SurfaceKSI-CNA-OFA Optimizing for AvailabilityKSI-CNA-RNT Restricting Network Traffic (Class A)KSI-CNA-RVP Reviewing ProtectionsKSI-CNA-ULN Using Logical NetworkingKSI-IAM-AAM Automating Account Management (Class A)KSI-IAM-APM Adopting Passwordless Methods (Class A)KSI-IAM-ELP Ensuring Least PrivilegeKSI-IAM-JIT Authorizing Just-in-TimeKSI-IAM-SNU Securing Non-User AuthenticationKSI-IAM-SUS Responding to Suspicious ActivityKSI-INR-AAR Generating After Action ReportsKSI-INR-RIR Reviewing Incident Response Procedures (Class A)KSI-INR-RPI Reviewing Past IncidentsKSI-MLA-ALA Authorizing Log Access (optional at B)KSI-MLA-EVC Evaluating ConfigurationsKSI-MLA-LET Logging Event TypesKSI-MLA-OSM Operating SIEM CapabilityKSI-MLA-RVL Reviewing LogsKSI-PIY-GIV Generating InventoriesKSI-PIY-RES Reviewing Executive SupportKSI-PIY-RIS Reviewing Investments in SecurityKSI-PIY-RSD Reviewing Security in the SDLCKSI-PIY-RVD Reviewing Vulnerability DisclosuresKSI-RPL-ABO Aligning Backups with ObjectivesKSI-RPL-ARP Aligning Recovery PlanKSI-RPL-RRO Reviewing Recovery ObjectivesKSI-RPL-TRC Testing Recovery CapabilitiesKSI-SCR-MIT Mitigating Supply Chain RiskKSI-SCR-MON Monitoring Supply Chain RiskKSI-SVC-ACM Automating Configuration ManagementKSI-SVC-ASM Automating Secret ManagementKSI-SVC-EIS Evaluating and Improving SecurityKSI-SVC-PRR Preventing Residual Risk (optional at B)KSI-SVC-RUD Removing Unwanted Data (optional at B)KSI-SVC-SIN Securing Information (Class A)KSI-SVC-VCM Validating Communications (optional at B)KSI-SVC-VRI Validating Resource Integrity7 required for Class A (and B, C)34 more required for B and C5 optional at B, required at C
7 + 34 + 5 = 46. Class A addresses the bronze 7. Class B addresses 41. Class C addresses every square. From fedramp.gov KSI references for Classes A, B and C.

The 7 Class A KSIs

  • Reviewing All Training KSI-CED-RAT
  • Logging Changes KSI-CMT-LMC
  • Restricting Network Traffic KSI-CNA-RNT
  • Automating Account Management KSI-IAM-AAM
  • Adopting Passwordless Methods KSI-IAM-APM
  • Reviewing Incident Response Procedures KSI-INR-RIR
  • Securing Information KSI-SVC-SIN

The full list by theme

  • Cybersecurity Education (1): Reviewing All Training
  • Change Management (4): Logging Changes · Redeploying vs Modifying · Reviewing Change Procedures · Validating Throughout Deployment
  • Cloud Native Architecture (8): Defining Functionality and Privileges · Enforcing Intended State* · Implementing Best Practices · Minimizing Attack Surface · Optimizing for Availability · Restricting Network Traffic · Reviewing Protections · Using Logical Networking
  • Identity & Access Management (6): Automating Account Management · Adopting Passwordless Methods · Ensuring Least Privilege · Authorizing Just-in-Time · Securing Non-User Authentication · Responding to Suspicious Activity
  • Incident Response (3): Generating After Action Reports · Reviewing Incident Response Procedures · Reviewing Past Incidents
  • Monitoring, Logging & Auditing (5): Authorizing Log Access* · Evaluating Configurations · Logging Event Types · Operating SIEM Capability · Reviewing Logs
  • Policy & Inventory (5): Generating Inventories · Reviewing Executive Support · Reviewing Investments in Security · Reviewing Security in the SDLC · Reviewing Vulnerability Disclosures
  • Recovery Planning (4): Aligning Backups with Objectives · Aligning Recovery Plan · Reviewing Recovery Objectives · Testing Recovery Capabilities
  • Supply Chain Risk (2): Mitigating Supply Chain Risk · Monitoring Supply Chain Risk
  • Service Configuration (8): Automating Configuration Management · Automating Secret Management · Evaluating and Improving Security · Preventing Residual Risk* · Removing Unwanted Data* · Securing Information · Validating Communications* · Validating Resource Integrity

* Optional at Class B, required at Class C. Older articles quoting 56 or 61 KSIs are using 2025 pilot counts.

Source: Key Security Indicators · class views A, B, C. Checked November 6, 2026.

How to get FedRAMP 20x certified, step by step

The order we work in with clients preparing for Class B or C. The rule behind each step is listed under it.

  1. Step 1: Confirm type, class and boundary

    Pick 20x or Rev5, your target class, and what’s in scope. You can’t pursue both types for the same offering.

    FRC-CSO-FCP · FRC-CSO-POP · MAS

  2. Step 2: Get listed in the Marketplace

    You must be listed before you apply. While listed, post progress every quarter and schedule an assessment within 2 years.

    FRC-APP-MLF · MKT-IIP-DCP · MKT-IIP-DLA

  3. Step 3: Map your tools to KSIs and automate

    Line up cloud, identity, logging and CI/CD against each KSI, then automate the checks. Start now: Class C needs 6 months of history.

    FRC-CSX-VVK · FRC-CSX-MOT

  4. Step 4: Build the package and trust center

    Write the Overview and Security Decision Record, in both readable form and valid JSON, and stand up a trust center.

    FRC-CSO-PKG · FRC-CSO-JSN · CDS-CSO-UTC

  5. Step 5: Independent assessment

    A FedRAMP Recognized assessor finishes it within 3 months before you apply (B and C). Older ones can be refreshed up to 9 months.

    FRC-APP-FIA · FRC-APP-USA

  6. Step 6: Apply yourself

    Submit the form with a package verified in the last 7 days. Advisors can help prepare, but can’t apply for you.

    FRC-APP-AFC · FRC-APP-FCP · FRC-APP-NTP

Source: Marketplace Listing · 20x Class C certification rules. Checked November 6, 2026.

The 20x certification package replaces the SSP with three living documents

A 20x package has three parts: an overview of your service, a Security Decision Record showing how you meet each rule, and an Ongoing Certification Report. The Security Decision Record replaces the old System Security Plan, and you keep it current rather than rewriting it each year.

Figure 5

Anatomy of the package, and where it lives

Your validationsrunning every dayFedRAMP-compatible trust centerProgrammatic access · access logged and kept 6+ months · agency access inventoryCertification Package · human-readable + JSONPackage OverviewSecurity DecisionRecordOngoing Cert.ReportService, boundary,contacts, assessorsummary, metadataReplaces the SSP.How each rule is met,KSI measures + historyEvery 3 months,plus a quarterlyreview (C: must)CPO-CSO-OVRSDR-CSX-KSICCM-OCR-AVLFedRAMPreviews, certifiesAgency customerspull data on demand
The trust center is not optional. It must share data without interruption and offer documented programmatic access. Rules: FRC-CSO-PKG CDS-CSO-UTC CDS-TRC-PAC CDS-TRC-ACL.

You also publish basic listing details in readable form and JSON: your FedRAMP ID, service description, contacts, secure configuration guidance, next report date and current assessor.

Rules: FRC-CSO-PKG SDR-CSX-KSI CDS-CSO-PUB

Source: Certification Package Overview · Security Decision Record · Certification Data Sharing. Checked November 6, 2026.

Staying certified: the clocks tighten with every class

This is the part most teams underestimate. Certification comes with fixed deadlines, and they tighten as the class goes up. Shorter bars mean less time.

Figure 6

How long you have, by class

1 h6 h1 day3 days1 wk2 wk1 mo3 motime allowed (log scale)Initial incident reportFinal incident reportVulnerability validationCertification package refreshOngoing Certification ReportPAIN-3 to 5 incidents · IEC-CSO-IIRafter resolution · IEC-CSO-FIRmachine-based resources · VDR-TFR-MVXkeep the package current · CPO-CSX-CPMevery class · CCM-OCR-AVLABCABCABCABCABC6 hours (should)6 hours1 hour3 business days3 business days6 hours1 month (should)7 days3 days3 mo (should)1 month2 weeks3 months3 months3 months
Bronze = Class A (faded where the rule is only a SHOULD), grey = Class B, black = Class C. Incident clocks start once you assign the incident’s impact (PAIN) rating.

Changes need notice, not approval

Significant changes no longer wait for FedRAMP sign-off. You notify instead:

Type of changeWhen to notify
Routine recurringNo notice needed
AdaptiveWithin 10 business days after you finish
Transformative30 business days before you start, 10 before, and within 5 after

Two more recurring obligations

  • Every 3 months: verify non-machine resources such as policies and people processes, at every class.
  • Every year: an independent assessment covering all applicable KSIs.

Rules: SCN-ADP-NTF SCN-TRF-NIP SCN-TRF-NFP SCN-TRF-NAF VDR-TFR-NMV IVV-CSX-AIA

Source: Incident Evaluation and Communication · Vulnerability Detection and Response · Significant Change Notification. Checked November 6, 2026.

FedRAMP 20x cost: the assessment is predictable, readiness is not

FedRAMP publishes no prices, but calls 20x the fastest and cheapest way into the federal market. Your budget has two parts:

  • The independent assessment is fairly predictable by class.
  • Readiness isn’t. It depends on how much of your product and infrastructure has to change.

Figure 7

Independent assessment: typical market ranges by class

$0$25K$50K$75K$100Kindependent assessment, USD · readiness is quoted separately after a gap assessment20x Class A20x Class B20x Class C3–4 months from SOC 25–8 months7–12 months (6-mo. history floor)$30K–$45Koptional at application, then annual$45K–$65Kwithin 3 months of applying$60K–$80Kwithin 3 months of applying
Not included: readiness work, remediation of code and infrastructure, tooling upgrades and your staff time. ControlSolid does not perform the independent assessment; these are typical market ranges for planning, not quotes.

Why readiness has no price on this page

Readiness is three kinds of work, and only the first is predictable.

Predictable

Compliance engineering

Mapping your tools to KSIs, automating the checks, writing the package and setting up the trust center. Grows with class: 7 KSIs at A, 41 at B, 46 at C.

The swing factor

Remediation

Code and infrastructure changes where a KSI can’t be met today, like passwordless login or central change logging. A few tickets, or a quarter of engineering.

Often forgotten

Tooling and upkeep

Higher-tier tool plans for API access, MFA priced per seat, and the recurring work after certification.

Any readiness price given before someone looks at your code and tooling is a guess. A gap assessment turns it into a list of what must change, by KSI, and a real quote.

Basis: FedRAMP publishes no prices. Ranges are ControlSolid planning estimates for the independent assessment, not quotes · Checked November 6, 2026

What this means for your starting point

You have SOC 2 Type II

Class A is built for you

Your report must be under 12 months old. You’ll share the full report and any bridge letter. Then plan the climb to B or C.

You were FedRAMP Ready

Ready still counts, for now

Ready is closed to new submissions, but a designation from the last 12 months qualifies you for Class A.

You hold Rev5

20x is a new program, not an edit

First, the December 7 vulnerability rules. Moving to 20x later means building KSI validation from scratch, not converting your SSP.

You’re starting from zero

Pick the fastest prerequisite

Class A needs a qualifying certification. Earn SOC 2 Type II first, or go straight to Class B with a full assessment.

Source: 20x Class A rules (FRC-CLA-ASF) · Important Dates. Checked November 6, 2026.

Objections we hear about FedRAMP 20x, answered

These are the assumptions that cost companies months. Each answer points to the rule behind it.

What people sayWhat the rules say
“20x is just a faster Rev5”It is a different machine. There is no sponsor, KSIs are proven by automated measurements, and the package is JSON. It is not always faster: Class C needs 6 months of KSI history and an assessment within 3 months of applying, and 20x isn’t available if you run your own infrastructure.FRC-CSX-MOT · FRC-APP-FIA
“We have ISO 27001, so we qualify for Class A”No. Class A accepts SOC 2 Type II, GovRAMP, or FedRAMP Rev5 (including Ready) completed within the past 12 months.FRC-CLA-ASF
“Our consultant or assessor can file the application”No. You must apply yourself. Advisors and assessors can help prepare the materials, but not submit them for you.FRC-APP-NTP
“We’re already Rev5 certified, so 20x doesn’t affect us”The December 7, 2026 vulnerability rules apply to every certified offering, Rev5 included. Moving to 20x later means building KSI validation from scratch, not converting your SSP.NTC-0014
“Let’s go straight to Class C to be safe”FedRAMP advises against it unless an agency contract requires it. Class C needs all 46 KSIs, at least 2 automated checks per KSI, and 6 months of history. Start at the lowest class your customers accept.Choose a Class · FRC-CSX-VVK

Source: Choose a Class · Choose a Type · Notice NTC-0014. Checked November 6, 2026.

FedRAMP 20x FAQ

Official references

Rules and references checked November 6, 2026. Applicability and revisions are rechecked for each engagement.

Next step

Find your gaps before your assessor does

Our gap assessment maps your controls, tools and code to your target class and shows exactly what has to change. Already certified? We can check your vulnerability program before December 7.

Related service: FedRAMP 20x Readiness & GRC Engineering →