by Michael Peters
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What The 2026 FedRAMP RFCs Mean For Cloud Providers

With the January 2026 release of multiple RFCs tied to the FedRAMP Authorization Act, the program is shifting from incremental process tweaks to structural modernization. This has been on the horizon for a while now, with the announcement of the FedRAMP 20x program. But this string of RFCs signals that the program is finalizing the finer points of this transformation. For CSPs and their compliance leaders, this is the point at which the realities of FedRAMP over the next decade come into sharper focus.

 

FedRAMP Authorization as Ongoing and Systemic

Historically, FedRAMP-vetted organizations that invested heavily in documentation completed a rigorous assessment and emerged with an authorization that served as a credential for federal sales. The 2026 policy direction reframes authorization as an ongoing system of trust validation where massive, scheduled audits give way to continuous compliance.

Across the RFCs, several consistent themes emerge

  • Automation of Evidence: Automation of evidence and artifacts will shift compliance away from manual documents to integrated data pipelines, enabling real-time visibility into control performance and reducing the operational burden of audits.
  • Greater Transparency into Costs and Program Performance: Greater transparency into costs and program performance will help agencies and providers better forecast timelines and budgets, while also driving market pressure toward more efficient and predictable authorization.
  • Expanded Participation Beyond Traditional Authorization Pathways: This opens the door for more providers to engage earlier in the FedRAMP lifecycle, increasing competition while accelerating innovation in the federal cloud ecosystem.
  • Emphasis on Continuous Assurance Rather than Static Approvals: Emphasis on continuous assurance reflects a move toward ongoing risk evaluation, with security posture monitored and validated continuously rather than relying on point-in-time authorization milestones.

 

A digital cloud with a red light shining on it from a security camera.

The 2026 FedRAMP RFCs

A January FedRAMP blog outlines a coordinated set of RFCs designed to operationalize the FedRAMP Authorization Act. Collectively, they represent a blueprint for how FedRAMP intends to modernize authorization, oversight, and ecosystem participation.

RFC-0019: Reporting Assessment Costs

This RFC proposes a structured mechanism for collecting and reporting pricing data related to FedRAMP assessments. The goal is to bring greater visibility into the true cost of authorization across the ecosystem, enabling policymakers to better understand barriers to entry and giving providers clearer benchmarks for planning. Over time, this transparency could help normalize pricing expectations and drive efficiency across the assessment marketplace.

Following the comment period, the GSA announced that it would not be including these cost reporting requirements in FedRAMP.

RFC-0020: Authorization Designations

RFC-0020 explores updates to how FedRAMP communicates authorization status, potentially moving beyond the traditional Low, Moderate, and High impact framing. The intent is to provide a more nuanced representation of security posture and maturity, aligning program terminology with statutory language and modern risk management practices. As a result of comments, FedRAMP will begin defining new classifications distinct from traditional FIPS-199 Impact Levels.

RFC-0021: Expanding The FedRAMP Marketplace

This proposal focuses on evolving the FedRAMP Marketplace into a more comprehensive ecosystem resource. It considers listing services earlier in their lifecycle, incorporating additional participant categories, and enhancing the information available to agencies (specifically, pricing). If implemented, the Marketplace could transition from a static directory to a dynamic decision-support environment that reflects readiness, capability, and progress.

Following comments, there are several in-depth changes to how organizations may appear on the Marketplace.

RFC-0022: Leveraging External Frameworks

RFC-0022 examines pathways for recognizing existing security certifications or assessments from other frameworks as part of FedRAMP onboarding. The objective is to reduce redundant evaluation work while maintaining visibility into risk, particularly for low-risk or pilot-use scenarios. This approach acknowledges the maturity of many commercial security programs and represents a step toward interoperability across compliance regimes.

RFC-0023: Rev5 Program Certifications Without A Sponsor

This RFC proposes a mechanism for services to pursue a FedRAMP program certification aligned with NIST SP 800-53 Rev. 5, even without an agency sponsor. The concept addresses a bottleneck in the authorization pipeline by allowing providers to maintain momentum while seeking federal demand. It also signals a move away from legacy constructs like FedRAMP Ready toward more flexible readiness indicators.

RFC-0024: Machine-Readable Authorization Packages

RFC-0024 introduces requirements for machine-readable compliance artifacts and authorization data. By shifting away from static documentation toward structured formats, FedRAMP aims to enable automation, analytics, and continuous monitoring at scale. This RFC is foundational to the program’s long-term vision of compliance as an operational data stream rather than a document set.

As of this writing, RFCs 0022 and 0023 have just closed. RFC 0024 closes on March 11th, 2026.

 

How Leaders Should Prepare for FedRAMP in 2026

Organizations preparing for or maintaining FedRAMP authorization should focus on three priorities.

  • Reassess Your Compliance Operating Model: Determine whether your approach is designed for periodic audits or continuous validation. The latter is rapidly becoming the program’s center of gravity.
  • Invest in Compliance Automation: Automation will reduce operational burden while positioning your organization for future policy expectations.
  • Reframe Your FedRAMP Compliance Priorities: As designations evolve, your messaging should emphasize operational maturity, resilience, and transparency rather than simply authorization status.

 

Take FedRAMP Authorization One Step at a Time with Lazarus Alliance

With all the changes coming down the pipeline for cloud providers in the federal space, it’s challenging to stay ahead of compliance requirements. Lazarus Alliance is an established FedRAMP 3PAO and security firm helping CSPs navigate these difficult waters in 2026 and beyond.

To learn more about how Lazarus Alliance can help, contact us. 

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