FedRAMP compliance checklist: Steps, requirements, and documentation essentials

FedRAMP compliance—the gateway to the $12 billion+ U.S. federal cloud market—exists to give federal buyers confidence in your security posture. If you’re compliant, it means you’ve adopted a standardized trust model and process. With Rev 5 becoming mandatory, the challenge of remaining compliant is more demanding than ever.

New requirements include more aggressive automation, ubiquitous machine-readable evidence, and, with strict remediation windows (30/90/180 days), if you miss a step, your Authorization to Operate (ATO) timelines can be delayed by months.

This article provides a practical, step-by-step checklist to help structure your plans as you adopt the FedRAMP framework. It covers every major phase—from careful definition of your system boundary to maintainable continuous monitoring—and points out how modern, secure-by-default tooling can help with the process. Use it to define your FedRAMP path and execute it on schedule.

What is FedRAMP compliance?

FedRAMP—the Federal Risk and Authorization Management Program—standardizes how U.S. federal agencies evaluate the security of cloud services. Born from the Federal Information Security Management Act of 2002 (FISMA) and built on the National Institute of Standards and Technology’s NIST 800-53 standard, it replaces the era of one-off agency audits with a single, reusable authorization model.

Any provider that stores or processes federal data must earn a FedRAMP Authorization to Operate (ATO) through a sponsoring agency. (The older process, which could include a provisional ATO (P-ATO) issued by a now-defunct Joint Authorization Board (JAB), has been sunset in 2024.) Once approved for an ATO, other federal agencies can rely on it and issue their own ATOs. So once you’re certified, you’re qualified to sell and contract (or subcontract) across the federal government.

As of 2025, Revision 5 has become the mandatory baseline, modernizing control mappings and supply-chain requirements. Next up is FedRAMP 20x, an acceleration effort that houses the government’s automation push by requiring faster remediation and machine-readable evidence. The two, when combined, define what compliance looks like in the immediate future: continuous, automated, and audit-ready by design. We cover Rev 5 and 20x in more detail in a separate post.

FedRAMP compliance requirements at a glance

FedRAMP is dense; it sources more than 400 controls from NIST 800-53 Rev 5. The controls, and their complexity, can be distilled to three repeatable disciplines: secure configuration, traceable evidence, and continuous maintenance.

• Security controls and technical safeguards: You’ll need strong encryption, role-based access, hardened systems, and timely patching. Rev 5 extended these expectations into the supply chain and added more privacy controls.

• Documentation and evidence: FedRAMP audits run on provable, auditable, and repeatable security work. And they’re backed by your system security plan (SSP), security assessment reports (SAR), and iterated plans of action and milestones (POA&M). The 20x update requires all of these to be automated.

• Continuous monitoring: You’ll perform monthly scanning and vulnerability reporting, and are expected to remediate issues within FedRAMP’s strict remediation windows.

These disciplines are the baseline operational layer that every FedRAMP checklist (including this one) builds on.

Step-by-step FedRAMP compliance checklist

This ten-step checklist distills what every provider must do to meet FedRAMP requirements, in approximate chronological order. For each step, we mention who typically owns it, what they produce, and the kinds of automation you’ll eventually be expected to implement.

Step 1: Define your authorization boundary and system scope

Owners: Product, security, and platform teams.

Actions: Diagrams and documentation for components, data flows, tenants, integrations, and natural system boundaries. Highlight external services and transitive controls

Output: Optimized boundary diagram, data classification lists, inventory of system components, and inheritance matrices.

Tips: Make each scope boundary small and defensible. Extra dependencies can exponentially increase requirements for evidence and reporting.

Step 2: Choose your FedRAMP baseline (low, moderate, high)

Owners: Security teams and the FedRAMP Program Management Office (PMO).

Do: Map data sensitivity and mission criticality to impact. Confirm with your FedRAMP sponsoring agency. Document your rationale and align it to PMO guidance for levels.

Output: Selected baseline and its justification. A plan for tailoring applicable controls.

Tips: Any changes can cascade into complete rewrites. Define and lock in your baseline as early as possible.

Step 3: Develop your System Security Plan (SSP)

Owners: Security team (with input and oversight from engineering teams).

Do: Map each Rev 5 control to concrete internal configs, policies, guidelines, and procedures. Align to boundaries, define security roles, and include security, hardening, and CI/CD requirements.

Output: SSP draft and a map connecting controls to specific system components.

Tips: Write explicit configs and guidelines, not generalities or platitudes.

Step 4: Harden systems and implement security controls

Owners: Platform and SRE teams.

Do: Enforce baselines for security and cryptography (eg, CIS benchmarks, STIG hardening guides, FIPS, SLAs for patch frequency, etc). Standardize images and VMs, and related OS and library versions. Start baking guardrails into your CI/CD and build pipelines.

Output: Hardened image baselines and build pipelines, policies-as-code, and controls to prevent drift.

Tips: Stack your controls and image composition to inherit security and cut churn.

Step 5: Conduct asset inventory and generate SBOMs

Owners: App security and platform teams.

Do: Maintain runtime inventory. Ensure that everything has a unique ID and that any changes are versioned and tracked. Auto-generate signed bills of materials (SBOMs) for deployables. Sign and log everything.

Output: Live asset catalog and matching, SBOMs.

Tips: Treat SBOMs as evidence to be stored and carefully protected (to signal compliance during audits), not as marketing materials (to be disseminated as a signal for transparency).

Step 6: Establish vulnerability scanning and patch management

Owners: App security and platform teams.

Do: Perform monthly (or more frequent) inventory on containers and hosts. Route inventory changes to the correct destination so they can be addressed if necessary. Operate under the required, strict, 30, 60, or 90-day SLAs. Document all work, including any suppressed patches, along with their rationales.

Output: Scan results, remediation logs, and any exception records.

Tips: Compose and sequence the work, anticipating having to redo parts of it, and optimize the sequences to avoid generating backlogs.

Step 7: Prepare a plan of action and milestones (POA&M)

Owners: Security teams and PMO.

Do: Log each finding, including owner(s), severity, fixes, follow-ups, and dates. Define clear priorities based on severity. Track issues to closure. Align the work with PMO and sponsor expectations.

Output: Initial POA&M and monthly updates.

Tips: Keep it boring by making it predictable, clean, standardized, well-structured, and consistently up to date.

Step 8: Engage a Third-Party Assessment Organization (3PAO)

Owners: Security, legal, and procurement teams.

Do: Select one or more 3PAOs to work with, scope the security assessment plan (SAP), schedule external testing, and stage any evidence required.

Output: SAP/security assessment report (SAR), test artifacts.

Tip: Do “dry-run” internal tests and rehearsals in advance. Avoid noise: fix spurious alerts, warnings, etc (aka paper-cuts) early.

Step 9: Achieve Authorization to Operate (ATO)

Owners: Leadership team, federal sponsor.

Do: Address any findings from your initial SAR, finalize and formalize communications, application package. Support any adjudication as necessary. Receive and store your ATO letter.

Output: ATO letter, acknowledgment for any residual risks, and plans for ongoing operations.

Tip: Keep all communications concise, clear, and factual.

Step 10: Maintain continuous monitoring (ConMon) and reporting

Owners: Security, platform, and engineering teams.

Do: Continue monthly scans. Keep high-level performance and success metrics. Update and document POA&M, incident reporting, and change controls as appropriate. Perform a formal, annual, end-to-end reassessment.

Outputs: Ongoing ConMon submissions, evidence roll-ups, and communications.

Tips: Automate evidence and all other work wherever possible. Read up on and plan to meet FedRAMP 20x requirements.

As you move through these steps, you’ll be assembling a lot of documentation: SSP, SAR, POA&M with signed SBOMs and proof of FIPS, STIG, and other compliance. These are the documents that keep you audit-ready. Ensure that you store them in a way that is easy to access, index, and refer to as you progress.

Documentation needed for FedRAMP compliance

The best teams treat documentation as an API contract, connecting auditors to engineers. And it’s the content of the documentation that’s relevant, not so much the volume. Strive for a system where everything you’re deploying documents itself. The documentation should include the correct amount of context and evidence for the auditors to do their work.

You’ll need to provide and maintain all of the following:

As the FedRAMP 20x rollout progresses, auditors will expect most of this documentation to be generated automatically from source systems. Plan to build the relevant automation into your build and deployment pipelines.

The limits of traditional FedRAMP approaches

Typically, when teams prepare for audits, they will tend to follow a waterfall approach. Build checklists, run scans, scramble to patch or remediate any issues, and manually document and collate the information needed for an audit. The scale and frequency of scanning that’s expected for FedRAMP typically exposes one or more of these three gaps:

• DIY hardened images: The industry has adopted “golden images” as a convention, as they’re usually the most practical way to enforce consistency across builds. These are tested and hardened images that serve as the foundation of CI and build processes. Building and maintaining them ad hoc and with homegrown processes quickly becomes unsustainable, though. Each new patch or dependency update can kick off a massive combination of scans, SBOM generation, and documentation updates.

• Relying on scanning to catch vulns: If you rely on scanning for images after they’re built and already in use, then by the time you detect a vulnerability, you’re already deep into your 30 (or 60 or 90) day clock for remediation. You’ll constantly scramble to keep up and are at high risk of missing deadlines.

• Minimal, unsupported images: As a way to limit complexity, some teams land on using maximally stripped-down open-source image builds at the base of their pipelines. These images may be less complex, but they are usually too stripped down. Since they focus on having a minimal footprint, they typically omit key system libraries, tools, and utilities (all of which you’ll have to jam in after the fact). Gaps will surface at audit time, as they typically won’t meet patch SLAs, provenance, and FIPS validation requirements.

The FedRAMP 20x rollout requires extra scrutiny of these types of gaps, since it focuses on and rewards prevention and automation.

Simplify and accelerate FedRAMP compliance with Chainguard

Most teams chase compliance and focus on optimizing their reaction speed—they patch faster and faster. A straightforward checklist like the one above is easy to execute once; the challenges come from doing it continuously.

Chainguard removes reactivity and eliminates large parts of the continuous compliance loop. You’re starting secure by default: our images, VMs, and libraries are built daily from source, scanned continuously, and shipped with zero known CVEs. You inherit compliance instead of building it from scratch each time.

Key advantages:

• Zero-CVE baselines that align directly with NIST 800-53 Rev 5 control families.

• Automatic SBOMs and signed provenance that drop straight into your SSP or ConMon package.

• FIPS and STIG alignment out of the box, removing weeks of configuration work.

• SLA-backed patch SLAs that meet 30/90/180-day FedRAMP deadlines without manual tracking.

• Daily rebuild automation via the Chainguard Factory, ensuring every dependency stays verified.

• Secure, signed libraries for your programming languages.

• Daily updates, allowing you to stay on top of the CVE backlog.

• Audit-ready transparency that’s drop-in compatible with your dev workflows.

When you use Chainguard, you’ve made a huge step toward converting compliance from a scramble downstream of your builds into a productive CI output. For more details, talk to an expert.