Prove every Key Security Indicator
20x Class B, C and D providers must include all KSIs in a FedRAMP independent assessment at least once per year. Class A must meet its alternative security framework instead.
FedRAMP 20x replaces long narrative packages with declarative rules, Key Security Indicators and recurring reports. NISTcompliance.ai turns those rules into daily work: validate KSIs with automated methods, run Vulnerability Detection and Response (VDR) and Vulnerability Evaluation and Reporting (VER) on your Class timeframes, share certification data through a trust center, and keep every package machine-readable.
Under the Consolidated Rules for 2026, certification is maintained continuously, not renewed by paperwork.
20x Class B, C and D providers must include all KSIs in a FedRAMP independent assessment at least once per year. Class A must meet its alternative security framework instead.
Required for every offering obtaining or maintaining FedRAMP Certification from Dec 7, 2026. The grace period ends Mar 7, 2027.
Every 20x provider, Class A included, supplies an Ongoing Certification Report to all necessary parties every 3 months. Class C and D must also host a Quarterly Review.
Providers must use a FedRAMP-compatible trust center to store and share FedRAMP Certification Data. Trust centers must offer documented programmatic access (CDS-TRC-PAC).
Sources: IVV rules, NTC-0014, CCM rules, CDS rules. FedRAMP Consolidated Rules for 2026, checked Oct 23, 2026. Not a substitute for the official rules.
FedRAMP describes 20x as the modern Certification Type and Rev5 as the legacy one.
20x Certifications do not need an agency sponsor. FedRAMP recommends 20x for cloud offerings built on FedRAMP Certified infrastructure or platforms.
Rev5 typically needs an agency sponsor. FedRAMP expects to retire Rev5 as a new Certification Type in mid-2027. It is the only option today for offerings that run their own infrastructure or need Class D.
Plan the move →FedRAMP anticipates piloting 20x Class D in late 2026, with a formal option expected in early 2027.
See the Classes →FedRAMP states that providers that do not adjust to the updated rules will lose their FedRAMP Certification, whichever type they hold.
Sources: Certification Types, Updating to 2026 rules. FedRAMP Consolidated Rules for 2026, checked Oct 23, 2026. Not a substitute for the official rules.
Map all ten KSI themes to automated methods and see which indicators meet your Class threshold.
KSI validation →PAIN-rated triage, Class timeframes, KEV due dates and a monthly VER report your team signs off.
VDR and VER →Certification data, Ongoing Certification Reports and VER history for the agencies that use you.
Trust Center →JSON and OSCAL output kept consistent with the human-readable versions by automation.
Packages →Evidence of implementation and effectiveness, ready for your annual independent assessment.
Assessor workspace →Quzara engineers who work the vulnerability queue with you when the clock is short.
Managed remediation →Summarized from FedRAMP's Certification Class guidance.
For existing commercial products with a recent independent assessment (FedRAMP Rev5, SOC 2 Type II or GovRAMP, within the past 12 months) and a mature security program. Adequate for most non-sensitive use cases. FedRAMP calls it the simplest way to get certified to obtain a customer.
Adequate for most Low security objectives and some Moderate or High ones.
Adequate for most Low and Moderate security objectives and some High ones. Intended for providers with an active customer base and an existing federal compliance program.
Adequate for most use cases regardless of security objective, excluding classified systems. Rev5 today; 20x Class D is expected to pilot in late 2026.
Sources: Certification Classes, Certification Types. FedRAMP Consolidated Rules for 2026, checked Oct 23, 2026. Not a substitute for the official rules.
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| Requirement | Class A | Class B | Class C | Class D |
|---|---|---|---|---|
| Automated methods per KSI | Optional (may) | At least 1 (should) | At least 2 (must) | At least 4 (must) |
| Annual independent assessment | May (must still meet its alternative framework) | Must | Must | Must |
| Ongoing Certification Report every 3 months | Must | Must | Must | Must |
| Synchronous Quarterly Review | May | Should | Must | Must |
| Evaluate vulnerabilities after detection (should) | 14 days | 7 days | 5 days | 2 days |
| Drift detection (should) | Every 3 months | Monthly | Every 14 days | Every 7 days |
| VER JSON history update | Monthly (may) | Monthly (should) | Every 14 days (should) | Every 7 days (should) |
| Monthly human-readable VER report | Not on Class A lists | Must | Must | Must |
Agencies should not authorize a Class A offering for more than 12 months unless it is actively seeking Class B, C or D.
FedRAMP advises that providers generally should not go straight to Class C or D unless an existing agency contract requires that level of commitment.
Sources: Agency Use rules, Certification Classes. FedRAMP Consolidated Rules for 2026, checked Oct 23, 2026. Not a substitute for the official rules.
From the FedRAMP 20x deadline schedule and notice NTC-0014. Rev5 follows a separate, later schedule.
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| Rules | Initial certification | Ongoing certification | Grace period ends |
|---|---|---|---|
| VDR and VER | Dec 7, 2026 | Dec 7, 2026 | Mar 7, 2027, then certification is revoked |
| CCM, CDS, CMU, CPO, FRC, IEC, IVV, MAS, SCN and SDR | Jul 4, 2026 | Jan 1, 2027 | First FedRAMP independent assessment started after Jan 1, 2027 |
The 2026 rules, Certification Types and what each provider must do.
Read the guide →How to choose a Class and what each one requires.
Read the guide →Phases, dates and what is due next.
Read the guide →Yes. FedRAMP notice NTC-0014 makes VDR and VER required for all cloud service offerings obtaining or maintaining FedRAMP Certification from Dec 7, 2026, with a grace period that ends Mar 7, 2027.
No. FedRAMP states that 20x Certifications are processed directly by FedRAMP and do not need an agency sponsor. Rev5 typically requires a sponsor or contract in advance.
Most 2026 rulesets apply to ongoing 20x certification from Jan 1, 2027, with a grace period that ends at the first FedRAMP independent assessment started after that date. VDR and VER follow the Dec 7, 2026 and Mar 7, 2027 dates. Rev5 providers follow a separate, later schedule for several rulesets, such as CDS on Aug 1, 2027.
FedRAMP designed Class A for existing commercial products that already hold a recent FedRAMP Rev5, SOC 2 Type II or GovRAMP assessment and run a mature security program. Plan the move to Class B or higher: agencies should not authorize Class A offerings for more than 12 months unless the provider is pursuing a higher Class.
Not yet as a formal option. FedRAMP anticipates piloting 20x Class D in late 2026 and expects it to become a formal option in early 2027. Rev5 is the path to Class D today.
Your Class, your KSI gaps, your VDR clock and what agencies will see in your trust center.