Independent FedRAMP Assessments by a Pursuing-Accreditation Third-Party Assessment Organization (3PAO)
RSI Security is currently pursuing A2LA accreditation as a recognized FedRAMP Third-Party Assessment Organization (3PAO). We are not yet authorized to perform formal FedRAMP assessments that result in an Authority to Operate (ATO). Once accredited, we will perform independent FedRAMP security assessments for Cloud Service Providers (CSPs) seeking federal authorization.
If you are a CSP preparing for FedRAMP authorization, we encourage you to register your interest now so we can contact you when our accreditation is complete.
Important: Until A2LA recognition is granted and RSI Security appears on the FedRAMP Marketplace, we cannot perform official 3PAO assessments. Organizations requiring an assessment today should engage a currently accredited 3PAO.
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What a FedRAMP 3PAO Assessment Delivers
Independent Verification
3PAO assessments provide an impartial, accredited evaluation of a CSP's security controls — replacing agency self-attestation with independently validated evidence required for federal Authority to Operate.
Alignment to FedRAMP and NIST Requirements
Assessments are conducted against NIST SP 800-53 Rev. 5 controls and the applicable FedRAMP baseline (Low, Moderate, or High), in accordance with FedRAMP PMO requirements and A2LA R311 standards.
Federal Market Access
Successful completion of a 3PAO assessment — including a Security Assessment Report (SAR) accepted by an Authorizing Official — is required for a CSP to achieve and maintain FedRAMP authorization (moving to the single "FedRAMP Certified" designation under CR26) and to sell cloud services to federal agencies.
The FedRAMP Assessment Process
FedRAMP assessments follow a defined process governed by the FedRAMP Program Management Office (PMO) and A2LA accreditation standards. Once authorized, RSI Security will conduct assessments in alignment with this process.
RSI Security
Readiness Assessment (Optional but Recommended)
An independent evaluation of CSP readiness against the applicable FedRAMP baseline controls before a formal authorization engagement begins.
- Evaluate CSP readiness against the applicable FedRAMP baseline controls
- Identify gaps before a formal authorization engagement, reducing downstream findings and rework
- Produce a Readiness Assessment Report (RAR) documenting the system's readiness posture
Note: The "FedRAMP Ready" Marketplace designation is being retired and restricted under CR26/RFC-0023, and legacy listings are not eligible for the new FedRAMP Certified designation. The readiness assessment itself remains valuable as independent gap-identification before formal assessment, regardless of the designation's status.
RSI Security
Authorization Scoping & Planning
Defining the authorization boundary and preparing the documentation that anchors the formal assessment.
- Define the authorization boundary and system categorization (FIPS 199: Low / Moderate / High)
- Validate System Security Plan (SSP) completeness
- Develop the Security Assessment Plan (SAP) in coordination with the CSP
RSI Security
Security Assessment Execution
Hands-on control evaluation across the applicable NIST SP 800-53 Rev. 5 baseline, executed in accordance with A2LA R311 requirements.
- Evaluate controls across applicable NIST SP 800-53 Rev. 5 baseline
- Execute examination, interview, and test assessment activities
- Perform penetration testing per A2LA R311 personnel requirements
- Validate objective evidence for each control
RSI Security
Security Assessment Report (SAR) & POA&M
Findings are documented, risk-determined, and packaged into the SAR required for the authorization decision.
- Document findings, control dispositions, and risk determinations
- Identify any open findings requiring Plan of Action & Milestones (POA&M) entries
- Finalize and deliver the SAR to the sponsoring agency and/or FedRAMP PMO
Sponsoring Federal Agency
Authorization Decision
Conducted independently by the sponsoring agency's Authorizing Official — separate from RSI Security's assessment activities.
- The sponsoring federal agency's Authorizing Official (AO) reviews the SAR
- AO issues an Authority to Operate (ATO) based on the assessment results
- FedRAMP PMO lists the authorized CSO on the FedRAMP Marketplace
RSI Security
Annual Assessments & Continuous Monitoring
Ongoing support to maintain authorization, adapting scope as systems and requirements evolve.
- Authorized CSPs undergo an annual assessment covering a defined subset of controls (not a full re-test of the entire baseline each year)
- Monthly continuous monitoring (ConMon) deliverables are submitted to the Authorizing Official
- Assessment scope is adjusted annually based on system changes and prior findings
- Under CR26, continuous monitoring is evolving toward automated, machine-readable validation
What Qualifies an Organization as a FedRAMP 3PAO
A FedRAMP Third-Party Assessment Organization (3PAO) is independently accredited by the American Association for Laboratory Accreditation (A2LA) and recognized by the FedRAMP Program Management Office.
To Qualify and Remain Recognized, 3PAOs Must:
- Complete a minimum of one year in A2LA's Cybersecurity Inspection Body Program prior to 3PAO consideration
- Achieve and maintain ISO/IEC 17020 accreditation as a Type A or Type C inspection body (Type B is prohibited to preserve independence)
- Comply with A2LA R311 — Specific Requirements: FedRAMP, including personnel qualification standards for senior assessors, junior assessors, and penetration testers
- Report and maintain Foreign Ownership, Control, or Influence (FOCI) status annually
- Be listed as a recognized 3PAO on the FedRAMP Marketplace
Only A2LA-accredited and FedRAMP-recognized 3PAOs may perform assessments that result in a valid Security Assessment Report (SAR) accepted by a federal Authorizing Official.
RSI Security's Current Status: We are in the process of completing A2LA accreditation requirements. We are not yet listed on the FedRAMP Marketplace. We will update this page when accreditation is granted.
FedRAMP Modernization: CR26 and FedRAMP 20x
FedRAMP is undergoing its most significant modernization since inception. The Consolidated Rules for 2026 (CR26) provide a single, stabilized rulebook, and FedRAMP 20x introduces an automation-first authorization path built on machine-readable evidence.
What's Changing, and Why It Matters for CSPs and 3PAOs
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A single "FedRAMP Certified" designation replaces the older "FedRAMP Authorized" language under CR26.
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Lettered Certification Classes replace the Low / Moderate / High impact labels (Class C maps to today's Moderate, where most CSPs land; Class D to High).
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Two distinct paths. Rev 5 and FedRAMP 20x are separate, non-transferable authorization paths — work toward one does not transfer to the other. Rev 5 remains the path for larger, more complex, or higher-impact systems; 20x suits cloud-native, well-scoped services.
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Key Security Indicators (KSIs) and OSCAL. 20x shifts validation from narrative control documentation toward measurable security outcomes (KSIs), with evidence expressed in machine-readable (OSCAL) format.
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Faster authorizations, for qualifying systems. 20x targets materially shorter timelines than the traditional year-plus Rev 5 path, though actual timelines depend on architecture, scope, and how cloud-native the system is.
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Continuous monitoring evolves from periodic manual submissions toward automated, near-real-time evidence pipelines.
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The 3PAO role evolves from manual document reviewer toward automation validator — verifying that machine-generated evidence accurately reflects implemented controls.
Availability is phased: wide-scale availability for the lower classes is targeted for the second half of 2026, with higher-impact (Class D) availability expected later, into FY27.
RSI Security is building its assessment methodology around both Rev 5 and FedRAMP 20x — including OSCAL-native evidence processing and continuous-monitoring validation — so that, at the time of our accreditation, we are positioned to support CSPs under either path.
Why FedRAMP Authorization Matters
FedRAMP is the federal government's standardized authorization program for cloud services. It follows a "do once, use many times" model — a single FedRAMP authorization is reusable across federal agencies, making it the most efficient path for CSPs serving the federal market.
Failure to Achieve or Maintain FedRAMP Authorization Can Result In
- Ineligibility to sell cloud services to federal agencies
- Potential loss of existing agency contracts upon expiration or renewal
- Competitive disadvantage in an increasingly FedRAMP-required procurement landscape
- Reputational risk in government and regulated commercial markets
Authorization demonstrates that your cloud service offering (CSO) meets verified federal security standards — validated independently, not self-reported.
RSI Security as Your FedRAMP 3PAO
RSI Security is pursuing A2LA accreditation to perform independent FedRAMP security assessments for Cloud Service Providers. Our background in NIST frameworks, federal compliance, and assessment methodology — including our authorized CMMC C3PAO practice — informs the rigor we are building into our FedRAMP assessment approach.
Once Accredited, Our Assessment Teams Will:
- Operate independently from advisory services, in compliance with FedRAMP independence requirements
- Apply A2LA R311-qualified senior assessors, junior assessors, and penetration testers to every engagement
- Deliver Security Assessment Reports (SARs) that meet FedRAMP PMO documentation standards
- Support both traditional Rev. 5 and FedRAMP 20x assessment methodologies
RSI Security is not yet an A2LA-accredited FedRAMP 3PAO. Engagement with RSI Security's advisory or readiness services does not constitute a FedRAMP assessment and will not result in an ATO.
FedRAMP 3PAO Assessment FAQs
What is a FedRAMP 3PAO and why is one required?
A 3PAO is an A2LA-accredited, FedRAMP-recognized organization that independently assesses a CSP's security controls. Federal agencies require a valid 3PAO-produced Security Assessment Report before issuing an Authority to Operate.
How is a readiness assessment different from an authorization assessment?
A readiness assessment evaluates a CSP's preparedness and produces a Readiness Assessment Report (RAR) identifying gaps before formal assessment. An authorization assessment independently verifies implemented controls and produces the Security Assessment Report (SAR) required for authorization.
Note: the "FedRAMP Ready" Marketplace designation is being retired under CR26/RFC-0023; the readiness assessment remains valuable as gap-identification regardless.Who issues the FedRAMP authorization?
The sponsoring federal agency's Authorizing Official (AO) issues the ATO. The FedRAMP PMO lists the authorized CSO on the FedRAMP Marketplace.
What is the difference between FedRAMP Moderate and FedRAMP High?
Impact levels are set by FIPS 199 categorization of the data a system handles. Moderate is the most common level, covering roughly 80% of authorizations — systems where a breach would have a serious adverse impact. High applies where a breach would have a severe or catastrophic impact, such as law enforcement, emergency services, or large-scale financial or health systems. Under CR26, these levels are being restructured into lettered Certification Classes (Class C corresponds to today's Moderate; Class D to High).
How does FedRAMP 20x affect my assessment?
FedRAMP 20x modernizes the authorization path with automated, machine-readable (OSCAL) evidence, Key Security Indicators, and continuous monitoring. Under CR26, it runs as a separate path from Rev 5, with wide-scale availability for the lower classes targeted for the second half of 2026 and higher-impact availability following into FY27. Which path fits your cloud service offering depends on your architecture, scope, and timeline — something to determine with your 3PAO during scoping.
When will RSI Security be available to perform FedRAMP assessments?
We are actively working through A2LA accreditation requirements. Register your interest below and we will notify you directly when our accreditation is complete.
Can the same 3PAO perform annual assessments after initial authorization?
Yes, provided independence requirements are met, no conflict of interest exists, and the 3PAO's A2LA accreditation remains active.
Register Your Interest
RSI Security is not yet authorized to perform FedRAMP assessments. If you are a Cloud Service Provider planning for FedRAMP authorization in the next 6–18 months, register now to be notified when our 3PAO accreditation is complete — and to discuss scope, readiness preparation, and timing without obligation.
Before accepting any FedRAMP assessment engagement, RSI Security will perform a conflict-of-interest review to confirm assessor independence, separation from advisory activities, and compliance with A2LA R311 requirements. Where a conflict exists, RSI Security will decline, restructure, or refer the engagement as required.