FedRAMP vulnerability scanning requirements explained

Federal agencies can only assess ongoing risk if you provide them with reliable scan data. Without it, your entire FedRAMP application package rests on incomplete information, and you’re at risk of losing authorization to operate (ATO). The FedRAMP framework treats vulnerability scans as the primary input to its continuous monitoring (ConMon) requirements. ConMon expects recurring evidence that systems are patched, hardened, and behave in ways consistent with the documentation in the rest of your compliance package, especially the System Security Plan (SSP).

In this context, requirements for scanning are prescriptive. They tell you where to scan, how often, what you have to report, and how quickly issues must be resolved. The expectations are meant to be unambiguous, so teams can reliably prepare for and handle the operational load that FedRAMP compliance imposes month after month. This article provides that breakdown in a straightforward, usable way. If you’d like to more generally learn about FedRAMP compliance, you can start with our FedRAMP compliance overview article.

What is FedRAMP vulnerability scanning?

FedRAMP uses the term “vulnerability scanning” in a narrow and precise way. Unlike some other security compliance regimes, you are expected to exactly comply with its structure and direction. If all you do is update your company guidelines and best practices, you won’t get very far with FedRAMP.

In this context, vulnerability scanning means you’ll perform authenticated, recurring scans of every in-scope system to identify known Common Vulnerabilities and Exposures (CVEs) and configuration issues. That’s everything in scope, including containers, hosts, registries, images, VMs, and supporting components. These results form the evidence record for continuous monitoring, Plans of Action and Milestones (POA&Ms), and risk reviews. Scan data must be cryptographically and directly tied to the assets defined in your authorization boundary and inventory.

In practice, this means that your scanning must become an operational discipline rather than an ad-hoc technical step. Every image version, configuration baseline, and software component must be traceable and scannable in an automated, repeatable, and predictable way. FedRAMP expects this process to remain stable across the life of your authorization to operate.

This context helps explain and frame most of the program’s explicit guidelines, especially its emphasis on scanning frequency, severity-based deadlines, and authenticated results.

Why does vulnerability scanning matter?

FedRAMP puts so much weight on vulnerability scanning because it’s one of the most frequently recurring signals agencies receive about the real state of your system. You’ll probably scan at least monthly (but usually more frequently than that); most other signals will only be checked during your initial ATO application and then annually. Scans verify whether patches have been applied under SLA, whether hardening measures are effective, and whether components are deviating from their approved configuration.

As a cloud service providers (CSP), you likely are relying quite heavily on partners, third-party cloud services, and open-source software, in a dynamic mix where vulnerabilities are a constant part of the operating environment. If signals from your scans become weak or inconsistent, auditors will assume that risks to your systems are increasing and proactively act to help protect federal organizations before anything “bad” actually happens. This can result in scrutiny during future audits, suspension of your Authority to Operate (ATO), or both.

Scan results inform and initiate updates for POA&Ms, monthly ConMon reports, and ultimately the decision to maintain or suspend an authorization. Missing scans, stale findings, or incomplete coverage are all considered risk indicators. These are some of the main reasons for the program’s strict enforcement of rules around scope, frequency, and remediation windows.

You’re expected to respond by turning scanning into an ongoing operational requirement, matched to the official rules governing how scanning must be performed.

Official FedRAMP vulnerability scanning requirements

FedRAMP publishes explicit rules for performing and reporting vulnerability scanning. These rules tie directly to the ConMon cycle via the CA-7 control. In NIST SP 800-53, which FedRAMP builds on, the CA family of controls focuses on Security Assessment and Authorization. You’ll become familiar with CA-7, since it’s the control that connects scanning to ConMon and helps agencies determine whether to consider a system maintainable and low-risk. Every CSP must consistently follow these requirements and match them for all aspects, including scope, cadence, authentication, remediation, reporting, and documentation.

These requirements form the baseline that auditors use when reviewing monthly submissions.

Scope of scanning

FedRAMP requires full coverage of every asset inside the authorization boundary, including container images, hosts, registries, VMs, and application components. Each asset must be represented in the inventory and mapped in a clear and unambiguous way; assets shouldn’t be confused with each other. Cryptography within the boundary must be FIPS 140-2/140-3 validated.

Scan frequency and cadence

Expect to scan very frequently. Monthly scanning is mandatory. In addition to the mandatory monthly scans, you must also run one after any major changes, new deployments, or updates that will impact your security posture.

Authenticated vs. unauthenticated scans

Authenticated scans are the default expectation, demonstrating that each scan has gone as deep as technically possible. Expect to give scanners unfettered access to the entire system that they are meant to scan. You can, as a rare exception, make a case and justify some unauthenticated scanning (for example, if credentialed access is not possible at all). But don’t count on it being permissible.

Remediation timelines

You must remediate findings on strictly enforced severity-based deadlines: 30 days for high-severity issues, 90 days for medium, and 180 days for low-severity issues. The clock starts either when an issue is live in production or when you first become aware of it (for example, by receiving a notification about a CVE from a vendor), whichever occurs first. The clock can easily start even if your scanner hasn’t run yet.

Reporting requirements

Each month, CSPs must submit scan results to the relevant auditors–that is, your authorization authority (AO) and/or the joint authorization board (JAB), as appropriate, via their dedicated ConMon channels. Make sure you include scan results, system deltas, and POA&M updates. Reports must reflect all assets and all findings without filtering.

Asset identification

Every scanned item must directly map to a unique identifier in the FedRAMP control for asset inventory, known as CM-8. (It’s included as part of FedRAMP’s inclusion of NIST SP 800-53 controls in its requirements.) It contains an authoritative list of all assets you have that are relevant to the FedRAMP authorization boundary. For containers, this includes image families, digests, and version lineage.

Documentation and evidence

CSPs must retain scan output, SBOMs, remediation proof, and evidence linking each fixed CVE to its corresponding asset.

Common challenges in meeting FedRAMP scanning requirements

On paper, FedRAMP’s scanning rules are clear. In practice, teams run into the same operational obstacles every month. Large environments, inconsistent inventories, and container sprawl make it hard to produce complete, authenticated scans on schedule. Many teams also struggle to keep scan outputs aligned with the CM-8 inventory, creating immediate audit friction.

Large CVE backlogs and alert fatigue

Container images often pull in hundreds of inherited CVEs. When these findings accumulate, POA&Ms grow faster than teams can reduce them, and remediation SLAs become difficult to meet.

Tool sprawl and integration gaps

Different scanners produce inconsistent results, especially across registry, host, and runtime scans. These mismatches slow down monthly reporting and force manual reconciliation.

Compliance delays and audit preparation burden

Incomplete evidence, mismatched asset identifiers, and version drift all extend the time it takes for ConMon reviews to finish. Teams often scramble to assemble proof of fixes, artifact lineage, and configuration baselines.

Inventory mismatches and CM-8 drift

Many teams struggle to keep their scan results aligned with the CM-8 asset inventory, particularly in containerized environments where images are frequently rebuilt or redeployed. Identifiers may be missing assets, contain duplicated entries, or have outdated image lineages. This would result in a mismatch with the inventory, and auditors will treat the scans as incomplete. Incomplete scans cause rescan cycles, POA&M expansion, and extended ConMon review. It’s one of the most common root causes of scan failures.

Hardening and configuration drift

FedRAMP expects scans to confirm that hardened baselines, scanner settings, and configurations match those described by the SSP, and meet or exceed DISA STIG hardening benchmarks. These baselines drift quickly in real environments. Small changes can break alignment and introduce new security findings. Auditors flag these discrepancies immediately, and so drift compounds remediation workload, since every deviation must be justified or corrected before submission.

Best practices for passing FedRAMP vulnerability scans

The core challenge in FedRAMP stems from the requirement to consistently produce review-ready results every month. Teams that standardize their workflows, automate evidence capture, and minimize the number of issues that appear in the first place have the best odds of success. These practices reduce audit friction and keep remediation windows manageable.

Automate scans and evidence collection

Integrate registry, CI, and host scanning to produce results on a predictable schedule. Capture scan logs, SBOMs, and timestamps automatically so ConMon submissions don’t rely on manual collection.

Prioritize remediation by severity and deadlines

Track findings within their 30-, 90-, and 180-day windows, and ensure that high-severity issues are addressed promptly. This reduces POA&M growth and aligns remediation work with FedRAMP expectations.

Monitor containers and registries continuously

Use immutable digests and automated rebuilds to ensure each image version is traceable. Continuous monitoring shortens detection time and prevents vulnerabilities from aging unnoticed.

Use secure-by-default components to reduce exposure

Minimal “golden” images, explicitly hardened in compliant ways, are an industry-standard solution to many of these problems. They reduce the number of inherited CVEs and minimize scanner noise. Such secure-by-default components make monthly reviews faster and improve the chances of meeting remediation SLAs.

Simplify FedRAMP vulnerability management with Chainguard

Staying compliant with FedRAMP starts with keeping vulnerability scans clean, complete, and authenticated every month. It can be a real strain keeping up while handling tool sprawl, conflicting scan paths, remediation deadlines, configuration drift, and the documentation required for ConMon. When scans surface hundreds of inherited issues or don’t align with the inventory, the entire compliance cycle slows down.

Chainguard reduces that burden by supplying hardened, low-noise components that produce cleaner scan results, smaller POA&Ms, and predictable evidence.

• Minimal images rebuilt daily, with 97% fewer CVEs

• Patch SLAs exceeding FedRAMP remediation windows (7-day critical, 14-day all others)

• SBOMs, signatures, and provenance are included with every artifact

• FIPS-validated crypto (as required inside of the FedRAMP boundary) and STIG-ready configurations (systems are assessed against DISA STIG hardening benchmarks)

• Developer-friendly integrations with existing pipelines, registries, and related tools

• Unified coverage, covering containers, libraries, and VMs, helping align with FedRAMP-mandated RA-5 scanning and related controls, like CM-8 (asset inventory) and CA-7 (ConMon)

• In production with FedRAMP-bound leaders like Snowflake, GitLab, and Domino Data Lab

If you’re looking for a container image solution that simplifies and accelerates your FedRAMP accreditation while saving your team time and effort, reach out today.

FAQs

How can organizations reduce the number of vulnerabilities flagged in FedRAMP scans?

The best way to reduce findings is to start with a secure foundation. Traditional base images ship with large numbers of inherited CVEs, which inflate POA&Ms and remediation workload. Chainguard Images are rebuilt daily and hardened, reducing inherited CVEs by approximately 97%, so scans reveal only issues that stem from work you directly own. This reduces backlog and keeps remediation within SLA windows.

What tools help automate FedRAMP vulnerability remediation?

Automation is essential to meet FedRAMP’s strict deadlines (and will become required with the 20x update as it rolls out). Many teams implement pipelines that automatically rebuild workloads when upstream patches land. Chainguard provides SLA-backed rebuilds (7 days for critical issues, 14 days for all others), so you don’t have to manually triage or backport fixes, and can keep remediation predictable across ConMon cycles.

How do SBOMs support FedRAMP vulnerability management?

SBOMs provide auditors with a component-level map of what was scanned and what each finding refers to. FedRAMP requires a clean, explicit trace that connects a vulnerability, the asset it affects, and the artifact deployed in production. Automatically generated SBOMs tied to each image make it possible to show scan coverage, confirm remediation, and justify POA&M entries without reconstruction work.

Can secure-by-default container images or VMs speed up FedRAMP authorization?

Yes. Pre-hardened, zero-CVE components significantly shrink pre-audit remediation work. Many delays in authorization to operate (ATO) packages come from inherited vulnerabilities in OS layers or base images. Using hardened, FIPS-validated, STIG-aligned components eliminates those findings before scanning begins, shortening assessment cycles and reducing rework.

How do vulnerability scanning requirements align with other FedRAMP controls?

Scanning is tied directly to asset inventory and continuous monitoring. Each finding must map to a unique CM-8 asset identifier, and monthly scan results become part of CA-7 reporting. This means inventories, scan schedules, and POA&M updates must stay synchronized. If these drift, ConMon submissions will stall or be rejected.

Why do organizations struggle with FedRAMP scanning compliance?

Most issues stem from inherited CVEs, inconsistent scanning tools, conflicting results, and difficulty meeting remediation deadlines. Scanners don’t fix anything—they only report. Without hardened components and automated rebuilds, teams fall behind, and POA&Ms expand faster than they can be closed. High-severity vulnerabilities frequently exceed the 30-day SLA in environments without automated patching.

What counts as an authenticated scan under FedRAMP?

An authenticated scan uses credentials to log into the asset being scanned. FedRAMP expects credentialed access for hosts, containers, registries, and images because it reveals vulnerabilities that unauthenticated surface checks cannot detect. Unauthenticated scans are allowed only in narrow cases and must be justified to the 3PAO.

When does the remediation clock start for a vulnerability?

The window begins when the vulnerability first exists in your environment, not when the scanner reports it. This includes the moment you import a vulnerable library, pull a base image, or a component you use is issued an advisory by a vendor. The clock starts before the next scheduled monthly scan.

What must be included in a POA&M for FedRAMP?

Each POA&M entry must list the vulnerability, affected asset (with CM-8 identifier), severity, justification, planned mitigation steps, and the expected remediation date. FedRAMP requires POA&Ms for all open findings—no filtering is allowed.

What happens if an asset is missing from the CM-8 inventory?

Any finding associated with an unlisted asset renders a scan incomplete. Auditors will request resubmission or a new scan cycle. Missing asset listings are one of the most common causes of ConMon delays.

Do container images require unique asset identifiers?

Yes. FedRAMP requires a unique identifier for each image family and version deployed in production. This is necessary for traceability between scans, SBOMs, and POA&M entries. The official container scanning guidance makes this explicit.

Are teams allowed to filter or suppress findings before submitting scan results?

No. FedRAMP requires full, unfiltered scan output. Any filtering—such as suppressing “low-risk” CVEs—is non-compliant and may lead to rescan requirements or review delays.

How often must container images be scanned?

At least monthly, plus after any significant change or deployment. FedRAMP treats image updates, dependency bumps, and rebuilds as triggers requiring a new scan cycle.

Do third-party components count as in-scope for scanning?

Yes. Anything inside the authorization boundary—including OSS dependencies, libraries, base images, and embedded services—must be scanned and included in the asset inventory.