Are FedRAMP Low, Moderate, and High Going Away?
FedRAMP 20x is changing how cloud service providers pursue federal certification. The familiar Low, Moderate, and High baselines remain important during the transition, but FedRAMP is moving toward a modern class-based model built around measurable security outcomes, structured evidence, automation, and persistent validation.
Executive Summary
FedRAMP Low, Moderate, and High Are Not Simply Disappearing Overnight
The traditional labels may become less central as FedRAMP 20x introduces certification classes, but federal cloud security will remain risk based.
A lower-risk SaaS application and a mission-critical federal cloud system will not receive identical security treatment. FedRAMP 20x changes how assurance is organized and demonstrated, not the underlying reality that different systems present different risks.
For years, providers have used Low, Moderate, and High to understand the expected control baseline, assessment effort, documentation requirements, and operational maturity associated with a federal cloud use case.
FedRAMP 20x introduces a more modern certification model using classes, Security Decision Records, Key Security Indicators, machine-readable certification data, independent validation, and persistent knowledge of the cloud service’s security state.
Providers should therefore think of the change as a transition in certification structure—not the removal of meaningful security tiers.
FedRAMP Low
Historically used for systems where a loss of confidentiality, integrity, or availability would have a limited adverse effect on federal operations.
FedRAMP Moderate
The most common baseline for many federal SaaS and cloud services where a compromise could cause a serious adverse effect.
FedRAMP High
Used for highly sensitive or mission-critical systems where a compromise could cause a severe or catastrophic adverse effect.
These impact levels helped agencies and providers select appropriate security baselines under the traditional FedRAMP model.
Higher potential impact generally resulted in broader security-control expectations, deeper testing, stronger operational requirements, more documentation, and greater continuing-monitoring responsibility.
The terminology also connected FedRAMP to the wider federal risk-management environment, including FIPS 199 impact categorization and NIST security-control baselines.
Why Is FedRAMP Changing the Certification Model?
Low, Moderate, and High are familiar terms, but they do not always explain the entire certification path, evidence model, assessment process, or level of assurance associated with a cloud service.
The traditional model also relied heavily on large control narratives, spreadsheets, screenshots, static reports, formal package reviews, and recurring submissions.
Modern cloud services operate differently. Infrastructure changes through code, security systems generate telemetry continuously, identities are managed through automated platforms, and cloud configurations can be measured through APIs.
FedRAMP 20x is designed to connect certification more closely to that operating reality.
Structured Evidence
Certification information can be processed, validated, compared, and maintained more efficiently than disconnected screenshots and reports.
Security Outcomes
Key Security Indicators connect important cloud-security outcomes to measurements, supporting evidence, validation, and remediation.
Automation
Repeatable security checks and evidence collection can reduce manual work and provide more current information.
Persistent Validation
Providers maintain an understood security state rather than relying only on evidence captured during a limited assessment window.
How FedRAMP 20x Changes the Traditional Baseline Model
FedRAMP 20x is more than a terminology update.
It changes how cloud providers organize certification information, document security decisions, measure outcomes, support independent validation, maintain evidence, and demonstrate the continuing security state of the cloud offering.
The traditional Rev. 5 model remains relevant during the transition, but the direction of the program is toward certification classes and a modernized assurance structure.
Impact Baseline and Package Model
Providers select Low, Moderate, or High and build a formal security package around the associated control baseline.
- Impact-level categorization
- NIST SP 800-53 controls
- System Security Plan
- Assessment reports
- POA&M and continuous monitoring
Certification Class and Validation Model
Providers follow class-specific assurance requirements supported by maintained decisions, KSIs, structured evidence, and validation.
- Certification classes
- Security Decision Record
- Key Security Indicators
- Machine-readable data
- Persistent validation
What Are FedRAMP 20x Certification Classes?
FedRAMP 20x uses certification classes to describe the level of assurance information a provider supplies for a cloud service offering.
The class structure can affect the applicable certification package, security measurements, validation, independent assessment, historical information, and ongoing requirements.
Classes should not be treated as simple one-word replacements for Low, Moderate, and High. They represent a different certification structure with their own requirements.
Providers should follow the current official rules for their intended certification class rather than assuming that a legacy baseline converts directly into a specific class.
Why Providers Should Not Invent a One-to-One Mapping
It may be tempting to assume that FedRAMP Low becomes Class A, Moderate becomes another class, and High becomes the highest class.
That type of simplified mapping may be useful as a rough planning illustration, but it should not be treated as a finalized compliance determination.
The certification classes describe assurance information and certification requirements under the current FedRAMP 20x rules. Traditional Low, Moderate, and High describe federal impact categorization and baseline expectations under the Rev. 5 model.
Providers should evaluate their target federal use case, data sensitivity, agency expectations, certification path, applicable rules, assessment requirements, and transition guidance.
What potential impact would result from losing confidentiality, integrity, or availability?
What certification class and assurance information are required for this cloud service and federal use case?
How are the applicable NIST SP 800-53 controls implemented and assessed?
How are security decisions, KSIs, measurements, validation, assessment, and continuing evidence maintained?
How is the authorization package maintained through continuous-monitoring submissions?
How is the intentional security state persistently validated and reflected in current certification records?
! Do Not Select a Certification Class From an Informal Mapping Chart
Use current FedRAMP rules, agency requirements, authoritative transition guidance, and the actual federal use case before committing to a certification path.
Not Sure Which FedRAMP Path Fits Your Cloud Service?
Emgage helps cloud providers define scope, evaluate baseline readiness, understand likely certification requirements, identify evidence gaps, and build a practical transition roadmap.
Review Your FedRAMP ReadinessWhat Happens to Existing FedRAMP Rev. 5 Certifications?
Existing Rev. 5 authorizations and certifications do not become meaningless simply because FedRAMP 20x is being introduced.
Providers already operating under Rev. 5 should continue maintaining their approved package, monitoring obligations, vulnerabilities, evidence, changes, assessment activities, and agency relationships.
Providers currently pursuing Rev. 5 should closely monitor official intake deadlines and transition instructions.
Existing Rev. 5 work may also support the transition. Architecture diagrams, asset inventories, policies, security procedures, vulnerability records, incident processes, assessment results, monitoring evidence, and control narratives may provide valuable source material for the modernized certification model.
The format and certification structure may change, but strong security implementation, reliable evidence, accurate boundaries, and mature operations remain valuable.
What the Transition Means for Cloud Providers
The right strategy depends on how far the provider has progressed, its federal sales timeline, target agencies, product architecture, existing documentation, evidence maturity, and expected assurance needs.
Build With FedRAMP 20x in Mind
Focus on a clear service boundary, cloud-native security, repeatable evidence, structured records, automated validation, accurate inventories, and measurable security outcomes.
Maintain the Current Path and Prepare for Transition
Continue approved Rev. 5 work while organizing evidence, improving automation, reducing documentation drift, and monitoring formal transition guidance.
Why Different Levels of Security Rigor Still Matter
Federal cloud systems do not all create the same risk.
A public information service with limited sensitivity does not require the same assurance as a cloud offering supporting mission-critical operations, sensitive information, law enforcement, emergency response, or national-security-related functions.
FedRAMP 20x does not eliminate these differences.
Higher-risk services should still expect deeper evidence, broader security capabilities, stronger validation, more independent assessment, greater historical information, tighter operational discipline, and more federal scrutiny.
The labels and certification mechanics may evolve, but federal agencies will continue evaluating whether the cloud service’s risk is acceptable for its intended use.
Common Misunderstandings About FedRAMP Baselines
“FedRAMP Low, Moderate, and High no longer matter.”
They remain relevant throughout the Rev. 5 transition and continue to represent important federal impact and security-planning concepts.
“Every cloud provider will follow the same 20x requirements.”
FedRAMP 20x uses certification classes and class-specific assurance expectations rather than one identical package for every service.
“A certification class is just a renamed impact level.”
Certification classes have their own package, evidence, validation, assessment, and ongoing requirements and should not be treated as automatic one-to-one replacements.
“Providers should stop all Rev. 5 work.”
Providers should follow their approved path and current official transition guidance rather than abandoning active certification programs.
“FedRAMP 20x lowers the security bar.”
The modernization effort is intended to improve efficiency and evidence quality while preserving appropriate federal security assurance.
“It is safer to wait until every detail is settled.”
Providers can prepare now by improving boundaries, evidence, security operations, documentation, validation, and remediation.
How Cloud Providers Can Prepare for the Transition
Confirm the Federal Use Case
Identify target agencies, data sensitivity, customer expectations, procurement opportunities, intended users, mission impact, and required assurance.
Understand the Current Path
Determine whether the provider is pursuing Rev. 5, preparing for FedRAMP 20x, or managing a transition between the two.
Define the Cloud Service Boundary
Document applications, infrastructure, accounts, regions, identities, pipelines, support systems, dependencies, integrations, and data flows.
Complete a Readiness Assessment
Identify security, evidence, documentation, vulnerability, governance, operational, architecture, and assessment gaps.
Centralize Evidence
Connect certification records to authoritative cloud, security, identity, vulnerability, logging, ticketing, repository, and operational systems.
Improve Automation and Validation
Automate high-volume evidence where practical and establish repeatable validation for technical and human-managed security processes.
Monitor Official Transition Guidance
Track current FedRAMP rules, class requirements, Rev. 5 deadlines, Marketplace guidance, assessment expectations, and provider transition instructions.
FedRAMP 20x Baseline Transition Checklist
Frequently Asked Questions
Are FedRAMP Low, Moderate, and High going away?
FedRAMP is transitioning toward certification classes, but traditional baselines remain relevant during the Rev. 5 transition and risk-based assurance is not disappearing.
Does FedRAMP 20x treat every cloud service the same?
No. Different certification classes and federal use cases can require different levels of evidence, validation, assessment, historical information, and assurance.
Does Class A automatically equal FedRAMP Low?
Providers should not assume an automatic one-to-one mapping. Certification classes and legacy impact baselines describe different aspects of the certification model.
Does FedRAMP High still matter?
Yes. High-impact federal systems still require strong security and assurance, even as FedRAMP’s certification structure and terminology evolve.
Should a provider stop pursuing Rev. 5?
Not automatically. Providers should follow their approved path, current intake rules, customer commitments, and official FedRAMP transition guidance.
Will existing Rev. 5 work be wasted?
Strong security implementation, evidence, policies, diagrams, inventories, assessment records, vulnerability management, and monitoring can still support future certification work.
What is the biggest difference under FedRAMP 20x?
FedRAMP 20x emphasizes certification classes, maintained security decisions, KSIs, structured evidence, automation, independent validation, and persistent knowledge of the security state.
What should SaaS providers do now?
Define the service boundary, complete readiness work, centralize evidence, improve security operations, monitor official guidance, and avoid committing to a path based on informal mapping assumptions.
The Bottom Line
FedRAMP Low, Moderate, and High are not disappearing in the sense that federal cloud risk and security rigor no longer matter.
FedRAMP is changing how cloud services are certified, how assurance levels are expressed, how evidence is structured, and how security is validated over time.
Traditional baselines remain important throughout the Rev. 5 transition, while FedRAMP 20x introduces certification classes and a modernized operating model.
Cloud providers should avoid oversimplified one-to-one mappings. The better strategy is to understand the federal use case, define an accurate boundary, follow current official rules, preserve mature Rev. 5 work, and build evidence processes that can support both current and future requirements.
The labels may change, but the need to demonstrate security at a level appropriate to federal risk will remain.
Prepare for the FedRAMP 20x Transition Without Guesswork
Emgage helps cloud providers understand their current baseline posture, evaluate likely certification requirements, define scope, organize evidence, identify readiness gaps, and build a practical transition roadmap.
Review Your FedRAMP Readiness