A FedRAMP Moderate baseline, now classified as Class C under the updated FedRAMP 20x framework, requires documentation and validation of over 300 controls–not an insignificant number, regardless of the enterprise.
Modern IT, however, rests on a network of digital infrastructure and vendor-supplied applications. If your app runs on a FedRAMP-authorized infrastructure provider, you benefit from the fact that those providers have already invested years and tens of millions of dollars in proving the security of systems to a Third Party Assessment Organization (3PAO).
By maximizing your Customer Responsibility Matrix (CRM) and building an inheritance-first architecture, organizations can offload their documentation and assessment burden to their underlying provider, reducing total time-to-ATO by 30% or more.
Shared Accountability and the Customer Responsibility Matrix
Understanding inheritance at the business level is necessary. Operating it correctly at the technical level is where the work actually happens, and where most organizations either gain or lose the efficiency they expected.
Types of CRM
The Customer Responsibility Matrix is the document that defines compliance and security responsibilities between a SaaS or infrastructure provider and their clients. Essentially, it outlines a perimeter of responsibility so there is a clear line between what the vendor provides and what you still need to do to maintain your compliance.
Generally speaking, there are three types of CRM:
- Inherited Controls: The provider bears 100% of the responsibility and has already documented and validated their implementation. Your obligation is to accurately reflect the inheritance in your System Security Plan (SSP) and ensure your configuration does not disrupt it. Physical and environmental controls fall almost entirely into this category for IaaS providers.
- Shared Controls: Both you and the provider have a defined role. Identity and Access Management (IAM) is a good example of this. Shared controls require the most careful scoping, because underestimating your share of responsibility here is one of the most common sources of late-stage assessment findings.
- Customer-Specific Controls: These are the client’s responsibility. Application-layer security, your software development lifecycle practices, your incident response procedures, your data classification and handling policies are all your responsibility.
The good news is that a well-scoped CRM dramatically reduces the size of customer-specific controls, focusing your internal compliance resources where they genuinely add value.
OSCAL and the End of Manual Inheritance
In 2026, manual inheritance documentation is increasingly out of step with how the FedRAMP PMO expects CSPs to operate. The Open Security Controls Assessment Language (OSCAL) has become the standard for machine-readable SSP documentation, and its import/export model is purpose-built for inheritance workflows.
In practice, this means your provider’s FedRAMP SSP should be in OSCAL format and contain structured, machine-readable control implementation statements. When you build your own SSP in OSCAL, you can programmatically import those provider controls, automatically populating your documentation with validated inheritance references rather than manually transcribing control descriptions.
Organizations that have not yet invested in OSCAL tooling, whether commercial platforms or open-source frameworks such as the NIST OSCAL reference implementations, should treat that investment as a prerequisite for an efficient authorization process.
Using Inherited Infrastructure as Designed for Compliance
Your provider has proven that their infrastructure is secure when used as designed. The moment an organization’s configuration undermines that design, the inherited control is broken and liability shifts entirely to the client.
Common examples that auditors routinely flag:
- Storage misconfigurations: Leaving a cloud storage medium publicly accessible invalidates data protection inheritance in the Media Protection and Access Control families.
- Unencrypted data in transit: Disabling or bypassing TLS for internal service communication undermines inherited network protection controls.
- Unrestricted IAM policies: Granting overly broad identity permissions within a provider’s IAM framework compromises inherited access control boundaries.
- Disabled logging: Turning off provider-native audit logging breaks the inherited Audit and Accountability controls that depend on it.
- Unapproved services: Using cloud services outside your provider’s FedRAMP authorization boundary leaves clients at risk of non-compliance.
Building an Inheritance Strategy for 2026
Maximizing inheritance can streamline compliance and lower the overhead needed to nail down an ATO… but it requires deliberate decisions early in the program lifecycle, when the cost of change is low.
A disciplined inheritance strategy follows a clear sequence:
- Choose the Right Authorization Class First: FedRAMP’s updated classification system (Class A through D) aligns with data sensitivity tiers. Your provider’s authorization must be at the same class level or higher than your intended offering. A provider with a Class B authorization cannot support a Class C (Moderate) offering through inheritance.
- Align with the 20x Pathway from Day One: FedRAMP’s 20x pilot has moved into wide-scale adoption and explicitly prioritizes inheritance-first architectures. The pathway rewards CSPs that demonstrate strong provider baseline leverage and minimizes the re-examination of already validated controls.
- Request and Review the Provider’s CRM Documentation: Every major authorized provider maintains CRM documentation that specifies, control-by-control, exactly where their responsibility ends, and yours begins. Request this documentation early, review it with your compliance team, and use it as the authoritative foundation for your own SSP scoping.
- Instrument Configuration Compliance from the Start: Once you have mapped your inherited controls, build automated enforcement around the configurations that protect those inheritances. Policy-as-code tools and provider-native compliance dashboards can validate that your configurations remain within the bounds required.
Efficiency Is a Security Strategy. Stay Efficient with Continuum GRC
The organizations that reach the FedRAMP Marketplace fastest in 2026 will not be the ones that wrote the most documentation. They will be the ones who wrote the right documentation — correctly scoped, inheritance-maximized, OSCAL-native, and built on infrastructure that has already done the heavy lifting.
We provide risk management and compliance support for every major regulation and compliance framework on the market, including:
- FedRAMP
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And more. We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.
Continuum GRC is a proactive cybersecurity® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect your systems and ensure compliance.
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