FedRAMP levels
FedRAMP High compliance: A step-by-step guide for organizations
Looking to streamline the work for FedRAMP compliance?
To work with U.S. federal agencies, cloud service providers (CSPs) must meet the strict cybersecurity requirements of the Federal Risk and Authorization Management Program (FedRAMP). The program defines three impact levels, Low, Moderate, and High, which differ in scope, rigor, and security expectations.
The FedRAMP High baseline sits at the top of this hierarchy, often regarded as a benchmark of mature security and operational resilience. It applies to systems that support law enforcement, emergency services, finance, and healthcare, and other critical government functions.
Earning FedRAMP High authorization is a complex initiative requiring planning for extensive controls, documentation, hardened architectures, and an environment that enables ongoing compliance. This guide’s a practical overview of all essential aspects, including:
- Scope of FedRAMP High
- Key authorization requirements
- Readiness steps
- Common challenges to watch out for
What is FedRAMP High?
FedRAMP High represents the highest, most rigorous security baseline under the FedRAMP. It applies to CSPs that handle Controlled Unclassified Information (CUI) or other highly sensitive federal data where the loss of confidentiality, integrity, or availability would have a severe or catastrophic impact on agency assets, operations, or individuals.
At this level, systems get categorized at the High impact level (per FIPS 199) when a risk assessment determines that a High-impact information type falls within the system boundary. Once classified, the CSP must implement the corresponding security and privacy controls from NIST SP 800-53, Rev. 5. These controls mitigate advanced cyber threats, often preventing breaches and severe consequences, such as:
- Failure of a medical device that would lead to loss of life
- Irreversible environmental damage
- Massive financial or operational losses
FedRAMP High authorizations are increasingly mandated today. More federal agencies are moving mission-critical operations to the cloud and classifying their systems at higher risk levels.
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Traditionally, High-impact systems would handle the most sensitive unclassified government data that directly impacts national security, law enforcement, or emergency services. While that is still true, the scope has also expanded to financial systems, health systems, and any other critical systems that could have a severe or catastrophic adverse effect. This includes not only the government’s data, but also data that involves the protection of life and financial ruin."
Who needs FedRAMP High authorization?
CSPs looking to serve federal agencies operating in high-impact cloud systems should pursue FedRAMP High to demonstrate their ability to safeguard sensitive data. Examples include:
- Systems hosting VA or Defense Health Agency (DHA) patient records
- Payment processing or treasury systems managing economic stability
- Emergency response and law enforcement agencies that use cloud systems
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CSPs pursue FedRAMP High to get listed on the FedRAMP Marketplace and bid for contracts that involve these systems. High-impact systems make up roughly 16% of marketplace listings, so the competition is lower, and FedRAMP High-authorized organizations have some strategic advantage in securing federal contracts.
{{cta_withimage44="/cta-blocks"}} | FedRAMP checklist
FedRAMP High impact level baseline requirements
FedRAMP High requires that a CSP implement the 410 security controls for the level as outlined in NIST SP 800-53 Rev. 5. Note that FedRAMP Rev. 5 (released in 2023) aligns fully with the updated NIST catalog, introducing modernized control language and new control families, including the Supply Chain Risk Management (SR) family.
Naturally, this level is the most demanding to meet as it involves a comprehensive control set to safeguard sensitive federal data. CSPs will likely need to focus more on the families with a higher volume of controls, such as:
Continuous Monitoring (ConMon) is one of the core obligations under FedRAMP. While it isn’t a standalone NIST control family, it’s an ongoing requirement derived from multiple NIST SP 800-53 controls that a CSP must maintain after receiving its Authority to Operate (ATO).
How does FedRAMP High compare to other levels?
The three FedRAMP baselines, Low, Moderate, and High, are based on the type of data CSPs handle and the severity of consequences in case of a security compromise. Each baseline increases the scope of security, control volume, and assurance requirements, which makes High the most scaled-up tier.
The following table compares FedRAMP High to Low and Moderate:
How to prepare for FedRAMP High authorization
When pursuing FedRAMP High authorization, be ready to invest in advanced security controls and continuous monitoring tooling. Here’re the essential steps you should follow:
- Define the requirements.
- Prepare resources.
- Hire a third-party assessment organization (3PAO) to conduct a readiness assessment.
- Implement and document security controls.
- Submit the package to the sponsor agency.
- Submit the authorization package to FedRAMP
{{cta_withimage44="/cta-blocks"}} | FedRAMP checklist
Step 1: Define the requirements
The first step is to define your scope. Conduct a FIPS 199-based assessment to identify data scope and sensitivity and assess your impact level. Next, identify which of your systems, applications, and environments fall within the FedRAMP scope.
A thorough scoping exercise is crucial for High authorization as any oversight could leave you with extensive late-stage work during 3PAO assessments, potentially delaying the authorization by months.
Step 2: Prepare resources
FedRAMP High is the most resource-intensive authorization as its requirements translate into higher costs, staff hours, sharper expertise, and investments in technology.
Here are some practical tips that can help you organize your resources effectively:
- Assign a compliance project manager or a team that will coordinate the process.
- Allocate financial resources according to scope, considering the cost of FedRAMP. High compliance can reach over $2 million for initial costs and ongoing assessments.
- Invest in a trust management platform to streamline compliance and automate time-consuming tasks, like collecting evidence and maintaining documents.
An often overlooked best practice is engaging with a FedRAMP consultant early on. The collaboration helps you manage requirements proactively and minimize scope creep and delays.
Step 3: Hire a 3PAO to conduct a readiness assessment
One of the key milestones in FedRAMP High authorization is finding and hiring an accredited 3PAO to validate the assessment. They are independent assessors authorized by FedRAMP to verify whether cloud systems and controls meet the expected standards.
To identify compliance gaps before the formal audit, 3PAO may conduct an interim review to issue the Readiness Assessment Report (RAR). The report is optional but helps CSPs remediate identified weaknesses, like missing security controls, before moving forward with the formal assessment.
Step 4: Implement and document security controls
Begin implementing or updating controls to address gaps and documenting them in the System Security Plan (SSP). Each control needs to be described in detail in the SSP, as it will be the main artifact your sponsor agency uses to validate compliance. High baseline authorization typically requires more extensive documentation and stronger technical standards compared to Moderate and Low levels.
After the controls are implemented, the 3PAO conducts the full security assessment and produces the Security Assessment Report (SAR). Along with the SSP, the SAR forms the core of the authorization submission package.
Step 5: Submit the package to the sponsor agency
Once the necessary gaps are addressed, submit your documentation package—including your SSP, RAR, and supporting evidence—to your sponsoring agency. They’ll review the package and decide whether to issue you an Authority to Operate (ATO).
The most common reasons for rejection are incomplete documentation and insufficient control implementation. This pattern is similar across both the High and Moderate baselines, but the High baseline leaves far less room for error, with lower tolerance for gaps, weak evidence, or residual risk.
Note: Under FedRAMP Rev. 5, the Agency Authorization is now the only path to achieving FedRAMP authorization. The legacy JAB Provisional ATO process is no longer available as an alternative option.
Step 6: Submit the authorization package to FedRAMP
After the sponsoring agency issues an ATO, the CSP submits the complete authorization package, including the SSP, SAR, POA&M, attachments, and required forms, to FedRAMP for review and inclusion in the FedRAMP Marketplace.
FedRAMP then verifies if the package meets formatting and completeness requirements and establishes the CSP’s continuous monitoring obligations.
Only after this submission and review is the service officially listed as FedRAMP Authorized and made available for reuse by other agencies.
Common challenges of FedRAMP High compliance
FedRAMP High compliance is challenging as it requires more than just documentation—it often necessitates significant re-engineering of the product. Common blocks include:
- FIPS 140-2/3 validation (The #1 blocker): Unlike lower standards, FedRAMP High strictly enforces the use of FIPS-validated cryptographic modules for all data at rest and in transit. Standard 'FIPS-compliant' algorithms are insufficient; the specific software libraries must be government-validated.
- Third-party dependency restrictions: You are only as secure as your supply chain. Any external service that impacts Federal Data must itself be FedRAMP Authorized at the same impact level (or higher). This often forces CSPs to abandon popular commercial tools that lack authorization and migrate to government-approved alternatives.
- Strict remediation timelines: FedRAMP High demands aggressive patching. Critical and High vulnerabilities must be remediated within 30 days. This operational tempo can be difficult to maintain without fully automated CI/CD and patch management pipelines. Depending on the number and frequency of remediation requests, the entire process from preparation to getting authorized for High can take from 12–24 months, on average.
- US sovereignty requirements: Because High systems often handle CUI or export-controlled data, many agencies will require all support and operations staff to be US Citizens located on US soil, limiting your global hiring pool.
- Heavy documentation: The SSP and supporting materials are extremely comprehensive for FedRAMP High, which can make the preparation process overwhelming.
- High financial costs: The overall cost of achieving FedRAMP authorization can reach hundreds of thousands to several million dollars. Annual, ongoing expenses for maintaining compliance after authorization can also be substantial.
Continuous monitoring: You need to maintain compliance by continuously monitoring your systems for vulnerabilities and security incidents. It can be challenging to plan this workflow at the scale of FedRAMP High, especially if you’re dependent on manual-heavy monitoring.
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Cost, planning, and expertise can certainly be major struggles for many organizations pursuing FedRAMP High, in addition to other key challenges—say, potential delays during PMO reviews, difficulties securing and maintaining an agency sponsor, and the ongoing commitment required to meet continuous monitoring obligations.
For FedRAMP processes to flow efficiently and coherently, you must leverage a compliance management solution like Vanta to automate time-consuming tasks such as collecting evidence, tracking control implementation, and streamlining monitoring.
Vanta: A faster, simpler way to FedRAMP High compliance
Vanta is a leading agentic trust solution that can simplify and organize complex authorization processes as FedRAMP High. The platform helps translate requirements into practical steps, set up continuous monitoring and high-priority alerts for focused action, and address compliance risks simultaneously.
With Vanta, you’ll be able to track controls, policies, and test results from a single dashboard. Your team will have clear visibility into the progress of granular tasks, including documentation. Vanta can also help with evidence collection by integrating with over 400 popular solutions.
Some key features of Vanta’s FedRAMP compliance product include:
- Pre-built, FedRAMP-aligned policies
- Continuous monitoring with security reports
- AI-powered policy management
- Partner network with trusted 3PAOs
Book a Vanta demo to get a more personalized walkthrough of how we can streamline your FedRAMP High program.
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FAQs
How long does FedRAMP High take?
Industry experience suggests that it takes roughly 12–24 months. The exact timeline depends on the scope, your system readiness, and the sponsoring agency.
Are there documentation requirements unique to FedRAMP High?
There are no unique document types for FedRAMP High, but this tier does require more extensive evidence and detailed SSP mapping to 410 controls. Additionally, it sets stricter continuous monitoring expectations than Moderate and Low levels.
Do I still need an agency sponsor for FedRAMP High?
Yes, you need an agency sponsor for FedRAMP High. Under Rev. 5, the Agency Authorization process is the only path to FedRAMP authorization today.
The FedRAMP 20x pilot is designed to streamline authorization without an agency sponsor, but it currently only applies to Low and Moderate impact systems, not High.
Will FedRAMP 20x eventually include High-impact systems?
FedRAMP 20x may eventually include High-impact systems as well, but this has yet to be announced.
Does FedRAMP High cover classified information?
No. It only covers unclassified federal information. Classified systems follow separate frameworks, such as DoD SRG or Intelligence Community (IC) programs.
Can a single system hold both High and Moderate data?
Yes, but in that case, FIPS 199’s “high-water-mark” applies. This means that the system must be authorized at the highest applicable impact level, which would be the High baseline.
However, such an organization needs to define system boundaries to separate different data types. It must also carefully manage interconnections so that Moderate data doesn’t compromise the security requirements of High.
What are the ConMon requirements for FedRAMP High?
The ConMon requirements for FedRAMP High are monthly vulnerability scans, POA&M updates, annual reassessments by 3PAO, incident communications, and Significant Change requests.
Does obtaining FedRAMP High automatically grant access to all federal agencies and data types?
Organizations often assume that a High authorization will automatically allow them access to all federal agencies and data types. However, that’s not the reality in practice, as authorizations are specific to individual agency use cases and don’t guarantee universal adoption.
Explore more FedRAMP articles
Introduction to FedRAMP
FedRAMP levels
FedRAMP requirements
Get started with FedRAMP:
Start your FedRAMP journey with these related resources.
FedRAMP Authorization Checklist
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The ultimate guide to FedRAMP: A requirements guide for authorization
Learn about FedRAMP authorization, from impact levels to compliance steps, to unlock opportunities with U.S. federal agencies.
Lessons learned from Vanta’s FedRAMP® 20x pilot program
A behind-the-scenes look at how Vanta navigated the FedRAMP 20x pilot.
