Get up to Speed on FedRAMP 20x

The Federal Risk and Authorization Management Program (FedRAMP) is evolving, and the “20x” modernization initiative marks the most significant update since the program’s inception. Designed to accelerate cloud adoption, strengthen security, and streamline authorization, FedRAMP 20x represents a shift toward continuous, automation-driven assurance rather than periodic, paperwork-heavy reviews.

For security and engineering teams, especially those running containerized workloads, these changes carry important implications for how you manage vulnerabilities, secure your software supply chain, and maintain your Authorization to Operate (ATO).

Let’s unpack what’s changing, and what it means for your FedRAMP strategy going forward.

What is FedRAMP 20x and why now?

FedRAMP 20x is a modernization effort to make FedRAMP more scalable, transparent, and adaptive to modern cloud-native technologies.

Unlike previous versions of FedRAMP, which were primarily agency-driven, FedRAMP 20x introduces a centralized, continuous authorization model. This means cloud service providers (CSPs) will no longer depend on individual agencies to pursue their ATOs. This change could significantly expand adoption and simplify market entry for SaaS vendors.

The modernization also includes a shift to machine-readable documentation, automation of assessment processes, and improved reciprocity across government systems. In short, it’s FedRAMP built for DevSecOps and modern software delivery.

Timeline and transition considerations

The transition to FedRAMP 20x will not happen overnight. For organizations already operating under FedRAMP Rev. 5, there’s no immediate mandate to switch. The current plan allows more than two years before 20x becomes a requirement for most authorization levels.

That said, Phase Two of FedRAMP 20x kicked off in October 2025, and the framework for Low and Moderate ATOs is expected to be formalized by mid-2026. To stay ahead of shifting standards, security and engineering teams should begin aligning with the new expectations now, particularly around automation, vulnerability management, and software provenance.

Notably, the Department of Defense will not extend reciprocity for 20x as it does with Rev. 5, meaning organizations working across both FedRAMP and DoD IL environments will continue to see demand for Rev. 5 ATOs alongside the new 20x requirements.

A shift in vulnerability management

One of the most impactful updates under FedRAMP 20x is the emphasis on continuous vulnerability management. Historically, FedRAMP compliance has focused on snapshot-in-time scans and periodic reports. The new model instead encourages real-time awareness, automated scanning, and faster remediation cycles.

Chris Hughes, CEO and Co-founder of Aquia, discussed the changes in our recent FedRAMP 20x webinar:

This change aligns closely with NIST’s SSDF and FedRAMP’s push for software supply chain transparency. CSPs must demonstrate not only that they’re scanning for vulnerabilities but also that they’re using SBOMs (Software Bills of Materials) to track components and prove that vulnerabilities are remediated or mitigated swiftly. This leads to a lot of additional work from CSPs, as every vulnerability must be triaged and assessed.

Under FedRAMP 20x:

• Continuous scanning becomes part of day-to-day operations, not a quarterly requirement.

• Agencies and third-party assessment organizations (3PAOs) will look for evidence of proactive vulnerability management workflows, not just the output of a static scanner.

• SBOM generation and validation at build time will become essential proof of compliance.

This evolution reflects the reality that vulnerabilities emerge faster than traditional ATO processes can handle, and continuous monitoring is the only way to keep pace.

Container security takes center stage

Containerized applications are now standard in federal systems, and FedRAMP 20x addresses this shift directly. The modernization framework recognizes that containers are both a tool for speed and a source of risk if not properly managed.

The updated guidance encourages:

• The use of minimal, immutable base images to reduce attack surface

• Automated image scanning and signature verification integrated into CI/CD pipelines

• Reproducible builds and digital attestations to verify that what’s deployed matches what was built and tested

• Continuous rebuilds to ensure patched, up-to-date software is always deployed

For engineering teams, this means moving beyond one-time security scans and adopting a DevSecOps approach that treats container integrity and provenance as core compliance artifacts.

FedRAMP 20x’s focus on automation aligns perfectly with containerized workflows, where each image can carry embedded evidence of its compliance posture, including SBOMs, signatures, and provenance attestations.

Preparing for FedRAMP 20x today

Even though most organizations won’t be required to fully comply with 20x until 2027 or later, preparing early will pay dividends. The modernization is designed around the same best practices driving broader industry change: secure-by-design development, minimal trusted components, and continuous verification.

Teams can start preparing now by:

• Building SBOM generation into their CI/CD workflows

• Transitioning to minimal, distroless container images

• Digitally signing and verifying all build artifacts

• Automating vulnerability scanning and patch pipelines

How Chainguard Containers accelerate FedRAMP compliance

For organizations navigating this transition, Chainguard Containers offer a direct path to aligning with FedRAMP 20x principles.

Chainguard provides secure, minimal, continuously verified container images, each built with signed provenance, reproducible builds, and zero-known CVEs at release. Every image includes a compliant SBOM, enabling traceability and simplifying evidence generation for FedRAMP documentation.

By adopting Chainguard Containers, teams can:

• Reduce their vulnerability exposure by using minimal, hardened base images

• Abstract away a significant amount of the work teams would normally need to do to triage and assess every vulnerability in their boundary, because Chainguard Containers start and stay at zero CVEs

• Automatically inherit compliance artifacts like SBOMs and digital signatures.

• Integrate continuous verification into CI/CD pipelines to maintain compliance posture in real time

• Shorten the path to ATO by demonstrating supply chain integrity aligned with NIST’s SSDF and FedRAMP 20x controls

In short, Chainguard helps teams operationalize the spirit of FedRAMP 20x: continuous security, provable integrity, and built-in compliance without slowing down development.

Move towards FedRAMP compliance with Chainguard

FedRAMP 20x represents the next generation of government cloud security. It’s faster, smarter, and built for the realities of DevSecOps and containerized delivery. For engineering and security leaders, it’s an opportunity to modernize compliance alongside infrastructure, embedding transparency, automation, and resilience into every layer of your stack.

And with Chainguard, that journey doesn’t have to start from scratch. By adopting secure, verifiable containers from the outset, teams can fast-track their path to FedRAMP readiness and stay ahead of the evolving compliance landscape.

But don’t just take our word for it. Hear from Chainguard customer Appian, who utilized Chainguard Containers to reduce vulnerabilities and achieve their FedRAMP compliance goals.

If you are interested in learning more about FedRAMP 20x, check out our recent webinar, “How Will Organizations Thrive Under New FedRAMP 20x Requirements,” and contact our team to learn more.