How to lower FedRAMP certification costs

FedRAMP is one of the most expensive and time-consuming authorizations a cloud service provider can sign up for. Budgeting for Third Party Assessment Organization (3PAO) reviews and documentation barely scratches the surface. The real costs come from months of engineering work addressing vulnerability backlogs, hardening requirements, and repeated rework delays. Plus, the longer it takes to comply, the more quarters of federal revenue you miss out on. Now that the Rev 5 update is fully in effect, and the push toward automation under FedRAMP 20x is rolling out, the costs of attaining compliance are rising further.

Different teams feel these costs differently. CFOs see the impact on budgets and ROI. CISOs bear the responsibility of documentation, audits, and the necessary staffing to maintain alignment with continuous monitoring. CTOs and platform engineering teams shoulder the heaviest burden: patching Common Vulnerabilities and Exposures (CVEs), building hardened images, and maintaining stable pipelines under strict remediation timelines.

Most organizations don’t start with a clear view of exactly what has to be done, so they underestimate how much time FedRAMP certification takes, or plan for tooling that reduces time and effort. This guide breaks down and helps you anticipate each cost driver, showing practical ways to reduce them. From eliminating CVE toil to shrinking the documentation footprint, these strategies help avoid rework late in the Authority to Operate (ATO) process.

For additional background and context on where FedRAMP is headed and why timelines keep tightening, start with our overview of the 20x automation initiative.

What is FedRAMP certification?

FedRAMP certification is the federal government’s framework for evaluating whether a cloud service is secure enough to handle federal data. It establishes a uniform authorization process, including architecture review, control assessment, vulnerability scanning, documentation, and continuous monitoring (ConMon). The work is deep: every component inside the system boundary must meet the required controls and produce traceable evidence.

The program defines three impact levels. Low covers public or low-risk information, Moderate covers controlled unclassified information, and High covers the most sensitive unclassified federal data. Moving up each tier significantly expands the surface area and is not a trivial update. As you move up, you’ll find more encryption requirements, more hardening standards, more scrutiny from assessors, and stricter consequences for falling out of compliance.

Providers obtain an ATO by working closely with a federal agency. It is possible (and recommended) to obtain a FedRAMP Ready designation (which lasts for 12 months) by obtaining some preliminary audits before starting the process. The path to authorization requires that the company build tight control over dependencies, images, baselines, and evidence. We cover the process in explicit detail in our Ask Sage case study.

FedRAMP folds in multiple federal standards, including the Federal Information Processing Standards (FIPS) cryptographic requirements used to validate encryption and key management. These sit alongside NIST 800-53 controls, STIG hardening guides (Security Technical Implementation Guides, produced by the Defense Information Systems Agency), and CIS benchmarks (Center for Internet Security configuration standards), all of which must align across the system boundary. Small misalignments, such as missing FIPS validation, components without documentation, and drift between builds, all create the kind of rework that drives up costs and delays certification.

How much does FedRAMP certification cost?

FedRAMP certification is expensive. Harvard Business Review reported in 2023 that “the cost to gain your FedRAMP certification can run anywhere from $400,000 to more than a million dollars.” The wide range reflects differences in system size, impact level, and the amount of remediation required before and during the initial assessment. It’s essential to note that this is the cost for obtaining your initial ATO. Maintaining your ATO comes with an ongoing monthly compliance cost.

Initial certification costs

These are the expenses teams incur on the path to achieving their first ATO. Scanning and 3PAO fees are external; the rest are typically a blend of specialised consultant fees or expansions for in-house teams.

• Third Party Assessment Organisation (3PAO) assessment fees

• Engineering time for hardening, dependency cleanup, and alignment with the FIPS and STIGs that are incorporated into FedRAMP

• Documentation development, including the System Security Plan (SSP), policies, diagrams, and procedures

• Boundary definition and architecture review

• Vulnerability remediation and patch cycles

• Tooling for scanning, asset inventory, logging, and evidence collection

• Additional 3PAO cycles triggered by missed 30/90/180-day remediation deadlines, which can extend the ATO timeline and increase consultant costs

• Rework in response to sponsor reviews (answering questions, clarifications, building supplemental evidence, and re-running some processes)

Ongoing certification costs

Once authorized, certification entails recurring costs, including:

• Monthly and yearly continuous monitoring (ConMon) submission preparation

• Monthly container, host, and dependency scanning

• Recurring patch cycles tied to the 30/90/180-day remediation windows, based on scan results

• Continuous evidence updates for configuration changes or boundary adjustments as systems evolve over time

• Annual assessment reports and ATO package refresh

• Staffing (engineering, security, and consultants) for FedRAMP program implementation, management, and audit readiness

• Evidence updates and patching, which compound quickly when automation isn’t in place

These numbers and lists only tell part of the story. Your cost drivers will also depend on how your system is built, how your teams are structured (will you be hiring more engineers vs. consultants), what’s within your boundary, and the extent of remediation required before assessment. Those factors vary widely and determine where teams end up with unanticipated spending.

What factors influence the FedRAMP certification cost?

Even when targeting the same FedRAMP impact level, organizations see dramatically different cost profiles. The variation stems from the complexity of the certified system, the cleanliness of the dependencies, and the team's preparedness for ongoing remediation. Underestimating this kind of scope early in the planning process is one of the most common mistakes. Teams that underplan for the work face delays of 6–12 months and may see related federal revenue pushed into the next fiscal cycle.

System size and complexity

Complex systems demand more scanning, documentation, and hardening.

• Broad service boundaries increase evidence volume; large and complex systems make it difficult to keep service boundaries tight

• Unless explicitly designed to be efficiently certified, microservices can multiply CVE and configuration surfaces. This is especially at the High level, where tight requirements also cover all internal communication (anything that goes over the wire for in-scope systems, whether between machines, humans, services, or otherwise, not just at the boundaries)

• Legacy or non-hardened components can require entire rewrites or major remediation

• Third-party services expand documentation scope

Authorization path: Your first ATO, reusing your ATO, and the Joint Authorization Board (JAB)

As of 2024, the Joint Authorization Board (JAB) no longer exists, and it has been replaced by the FedRAMP Board. As a result, JAB-issued provisional ATOs (P-ATOs) are no longer available. Your path towards your first ATO starts by applying through an existing agency. All previous P-ATO work has been streamlined into that first ATO application. For your second or any additional ATOs (each issued by a separate agency), you will reuse all of your existing ATO work.

Expect your first authorization path to match the rigor expected by your issuing agency and the level you’re aiming for, with Low ATOs requiring the least rigor and High the most. Once you’ve been issued an ATO at one of the three levels (Low, Medium, or High), other agencies will accelerate the process for issuing ATOs for their systems.

For your second (and subsequent) ATOs, agencies will formally request access to and review the materials you’ve already submitted for any existing ATOs. If your existing ATO matches or exceeds expectations, additional ATO will be quick to obtain (and maintain). If it does not match, such as when you need to transition from Low to Medium or an agency has specific controls that are more stringent, expect to be asked to do additional work. You’ll likely have to increase your controls to meet the strictest requirements amongst all the agencies you’re looking to work with, and then have that work apply to all of them.

Occasionally, you may also be asked to provide additional delta scans or information as part of ConMon to a specific agency to meet their unique requirements.

Security and engineering remediation needs

Your initial security posture has a significant impact on the total cost.

• High CVE counts from your security assessment drive repeated remediation cycles, and growing CVE backlogs drive additional scrutiny and costs

• FIPS and STIG alignment, if not already planned for in your systems, will require major refactoring

• Patch windows are fast and are fully in effect during assessments, increasing engineering load in parallel to the rest of the audit work

• Detecting and fixing drift (mismatches between documentation, certification, and the actual contents of your software) between builds increases rework

Documentation and audit preparation

Documentation is often the longest tail in the process; FedRAMP expects your security posture to be explicit and intentional, which means you’re expected to document what you’re doing and then demonstrate that you’re doing it.

• System Security Plans (SSPs) can be quite deep, and achieving cross-team alignment on them is time-consuming

• Policies, procedures, and configuration records are explicitly specified and required, so if you are missing any, you may have to restart the entire process

• Each FedRAMP-specified security control requires its own fully independent documentation trail, and there are a lot of controls: ~125 at Low, ~325 at Medium, and ~421 at High

• Responding to sponsor questions and clarifications is time-consuming and can require redoing entire workflows after submission

These cost drivers don’t go away after you achieve your first ATO. The same system characteristics carry directly into the ongoing work required to stay compliant. You’ll need to continuously monitor boundary size, dependency quality, remediation load, and documentation depth on a monthly basis (for maintaining your ATO) and a yearly basis (for updating your ATO). Planning for the ongoing effort that’s required will help you make the long-term cost curve far more predictable.

Ongoing costs for maintaining FedRAMP compliance

FedRAMP requires providers to maintain and report on the same security posture they met during their initial ATO every month, and to update their ATO on a yearly cadence. You’ll see a steady operational cost line that affects your security, engineering, and compliance teams each month. Keeping these predictable, especially if they are substantial, can take some effort. Here are some things to keep in mind.

Continuous monitoring and reporting

FedRAMP’s monthly continuous monitoring (ConMon) cycle is mandatory and non-negotiable. It’s worth planning for and optimizing your process to make sure you’re ready to:

• Prepare monthly ConMon submissions

• Update scan results for containers, hosts, and dependencies

• Perform follow-up remediation and evidence for outstanding findings

• Coordinate with the sponsoring agency on any deviations

• If you’ve obtained multiple ATOs, you may be expected to provide additional, agency-specific, delta reports, covering differences in rigor for ATO requirements

Recurring scans and patch cycles

You must continuously scan for vulnerabilities and patch all components within the boundary. You’ll be using the outputs from your scan and patch processes to produce your ConMon submissions. The results from cycles can increase your ConMon report frequency and depth beyond the default minimum monthly FedRAMP requirements.

• You must run monthly authenticated scans across the full system boundary

• Tie your patch cycles to the relevant 30/90/180-day remediation deadlines for your ATO

• Re-scann and re-verify after every bug fix or patch

• Also, rescan after any system changes or deployments to prod

Configuration drift management

You must keep your documentation current and up-to-date for all your systems. Any mismatch between documentation and the deployed system creates immediate rework. You should plan for:

• Drift detection across images, libraries, and infrastructure

• Any necessary updates to the System Security Plan (SSP)

• Immediate evidence regeneration after any configuration changes

• Re-baselining whenever services or dependencies shift

Annual assessment and package refresh

You must revalidate and refresh your ATO annually. To prepare for this process, you’ll want to plan for:

• Annual third-party reassessment

• Updates to all control documentation

• Policy and procedure reviews

• Full package resubmission to the sponsoring agency

While these ongoing requirements mirror the same cost drivers for your initial ATO, they can be significantly more disruptive, since any drift or missed deadline immediately increases operational load. Let’s look at some common mistakes that can compound across monitoring cycles.

Common mistakes that can increase costs

FedRAMP is a sequential process that rewards careful planning and forethought. Early mistakes tend to ripple forward and amplify. What might look like a small slip at the start, such as an unclear control implementation or recurring vulnerable dependency, can compound and amplify, driving costs much higher than most teams expect. The de facto industry standard approach to avoiding these expensive scambles is to aim to be secure by default.

DIY hardening without maintenance resources

Manually hardening base images or libraries is viable at the start and is an attractive option for quickly getting to the initial ATO. Unfortunately, maintaining them across continuous CVE releases becomes unsustainable and balloons in time and resource cost.

Secure-by-default alternative: Regularly rebuilt and hardened images purpose-built by specialised service providers remove the backlog entirely and prevent repeated remediation cycles.

Treating certification as a one-time event

Many teams plan only for the initial ATO, assuming it’s the most intensive part of the process. They underestimate continuous monitoring, assuming it’s a much lighter load. This incorrect assumption leads to missed remediation windows, evidence drift, and recurring rework.

Secure-by-default alternative: Continuously, automatically updated and verified components reduce ConMon workload because patched, optimally scoped builds will align with monthly scanning requirements out of the box.

Underestimating the documentation burden

FedRAMP expects detailed, verifiable documentation that explicitly matches to exactly what you’re running in production. Missing policies, incomplete diagrams, or shallow SSP sections can trigger repeated review cycles and lead to a forced remediation requirement.

Secure-by-default alternative: If your CI and build processes come with built-in SBOMs, signatures, and provenance, you’ll spend less time and money on documentation, since evidence is produced (and can be checked against your SSP and efficiently updated) automatically with every build.

Starting from vulnerable images

It is tempting to start from a minimal OSS base image, as small images, in theory, reduce the potential attack surface. These images, though, are typically not optimised and maintained for FedRAMP compliance and will often be out of date by hundreds of CVEs, despite being small. A shortcut at first translates into immediately inflated remediation work, as issues may only become apparent late in the scan process and then require specialised research, a rebuild of the base image from scratch, and a full run of the CI, build, test, and scan cycle.

Secure-by-default alternative: Start from golden images that are optimally sized and separately scanned, ensuring they are zero-CVE. They will eliminate most early engineering toil and reduce the potentially high volume of 3PAO findings tied to inherited vulnerabilities.

How to reduce FedRAMP certification and maintenance costs

Reducing FedRAMP costs primarily involves eliminating the sources of rework that arise during assessment and persist throughout continuous monitoring. The approaches below target the root causes of inflated engineering, remediation, and documentation efforts.

Start with secure, hardened components

Hardened, minimal, continuously rebuilt containers and libraries remove most inherited vulnerabilities before scanning even begins. Building these in-house is time-consuming and expensive, relative to buying them from specialised vendors. This reduces remediation cycles, minimizes 3PAO findings (focusing them on work where you are a domain expert), reduces scope for system boundaries, and narrows the system's attack surfaces.

Automate SBOMs, signatures, and other evidence collection

Evidence production is one of the most expensive recurring tasks in the FedRAMP compliance process. Automatically generated SBOMs, cryptographic signatures, and provenance attestations minimize manual documentation and ensure every build is audit-ready. Much of this automation will become a standard requirement for compliance once FedRAMP 20x is adopted as the standard.

Minimize CVE accumulation through continuous updates

Daily-rebuilt base images prevent vulnerability backlogs from forming. This reduces pressure during 30/90/180–day remediation windows and stabilises cost across monthly continuous monitoring cycles. For High compliance, continuous near-zero CVE backlogs are expected.

Use secure-by-default components to control long-term spend

Starting with components aligned to FIPS, STIG, and CIS baselines eliminates large categories of refactoring, avoiding expensive realignments late in the assessment and keeps drift under control after the ATO is granted.

How Chainguard lowers FedRAMP certification costs

The highest costs associated with FedRAMP compliance stem from the rework of lengthy and complex processes. That includes rebuilding images, remediating systems once vulnerabilities are detected, regenerating evidence, correcting drift, updating documentation, and re-running scans after missed deadlines. Chainguard reduces these costs by giving teams base components that start and stay compliant. We eliminate large swathes of the kind of rework that slows authorization and inflates budgets with:

• Continuously rebuilt, minimal images that prevent vulnerability accumulation, and reduce rework during 3PAO testing and monthly ConMon cycles.

• SLA-backed patch windows that exceed FedRAMP requirements, keep remediation predictable, and prevent the costly rework triggered by missed deadlines.

• FIPS-validated and STIG-aligned artifacts that sidestep the repeated configuration corrections and full pipeline reruns that typically show up late in reviews.

• Automatically generated SBOMs and provenance eliminate the manual evidence regeneration that drives documentation rework.

• Secure-by-default libraries and VMs reduce ongoing maintenance and prevent dependency-level drift that creates recurring remediation work.

If you’re looking for practical ways to limit rework and stabilize your FedRAMP cost curve, we can help you choose the right components to start with. Talk to an expert.