How to Choose the Right FedRAMP Authorization Level for Your Organization

Achieving FedRAMP authorization represents a significant milestone for cloud service providers looking to serve the federal government market. The Federal Risk and Authorization Management Program (FedRAMP) creates a standardized approach to security assessment, authorization, and continuous monitoring that enables government agencies to adopt cloud technologies with appropriate security protections. For cloud service providers, FedRAMP authorization opens doors to the expansive federal marketplace, a sector that spends billions on cloud services annually.

However, the path to FedRAMP authorization is undeniably challenging. The certification process demands substantial investment in security controls, documentation, third-party assessments, and ongoing compliance activities. Organizations often underestimate the time, resources, and organizational commitment required to achieve and maintain authorization. A successful FedRAMP journey typically takes 6-18 months, requires dedicated personnel, and involves significant financial investment that can range from hundreds of thousands to millions of dollars depending on the authorization level pursued.

Given these substantial investments, selecting the appropriate FedRAMP authorization level becomes a critical strategic decision. Pursuing an unnecessarily high level can waste resources and delay market entry, while choosing too low a level may limit your addressable market and require a subsequent upgrade. The decision requires careful analysis of your service offering, target federal customers, data sensitivity, business objectives, and resource constraints.

This guide provides expert recommendations to help cloud service providers navigate this crucial decision point. By understanding the requirements, benefits, and considerations associated with each authorization level, you can make an informed choice that aligns your security investments with your federal market strategy and maximizes your return on investment in FedRAMP authorization.

FedRAMP Authorization Levels

FedRAMP authorizations come in three distinct impact levels – Low, Moderate, and High – each designed to protect federal information based on the potential impact of a security breach. Understanding what each level enables your organization to do is essential for making an appropriate selection.

FedRAMP Low authorization establishes an entry-level security baseline appropriate for systems where the loss of confidentiality, integrity, and availability would have a limited adverse effect on agency operations, assets, or individuals. This level enables cloud service providers to offer solutions for non-sensitive government information such as public-facing websites, collaboration tools without sensitive data, training systems, and development environments. While Low represents the most accessible authorization level, it limits providers to the smallest segment of the federal market dealing primarily with non-sensitive information.

FedRAMP Moderate authorization establishes a more comprehensive security baseline suitable for systems where a security breach would have a serious adverse effect on agency operations, assets, or individuals. As the most commonly implemented level across the federal government, Moderate enables providers to handle the majority of federal systems containing Controlled Unclassified Information (CUI). This level opens doors to email systems, case management applications, financial planning tools, procurement systems, and most agency operational systems. Moderate authorization gives providers access to the largest portion of the federal cloud market, representing the optimal balance between security investment and market opportunity for many cloud services.

FedRAMP High authorization implements the most rigorous security controls for systems where a breach would have a severe or catastrophic adverse effect on agency operations, assets, or individuals. This level enables providers to serve highly sensitive federal systems supporting mission-critical operations, law enforcement, emergency services, healthcare, financial management, and other high-impact functions. While High authorization requires the most substantial security investment, it allows providers to compete for specialized, high-value contracts with agencies handling the most sensitive unclassified information, including components of the Department of Defense, Department of Justice, and Department of Homeland Security.

Each ascending level expands a provider’s addressable market while requiring progressively greater security investment. The appropriate level depends on the sensitivity of the information your cloud service will process and the specific federal customers you aim to serve.

FedRAMP Requirements for Each Level

Each FedRAMP authorization level mandates a specific set of security controls and requirements that become progressively more stringent at higher levels. Understanding these requirements is essential for estimating the investment needed for each authorization level.

FedRAMP Low Authorization Requirements

FedRAMP Low requires implementation of 125 security controls across 17 control families as defined in NIST Special Publication 800-53. These controls address basic security needs such as access control, audit logging, configuration management, and incident response. While fewer than higher levels, these controls still establish a meaningful security baseline that exceeds typical commercial security practices.

The documentation required for Low is less extensive than higher levels, with a more streamlined security package. Continuous monitoring requirements involve annual assessments with less frequent reporting compared to higher levels. For many organizations, Low represents the most approachable entry point to FedRAMP, requiring the least investment while still establishing federal-grade security practices.

FedRAMP Moderate Authorization Requirements

FedRAMP Moderate substantially increases security requirements with 325 controls across the same 17 control families. These controls implement more rigorous security practices such as multi-factor authentication for privileged accounts, comprehensive event logging, advanced incident response capabilities, and robust change management procedures.

The documentation burden increases significantly at the Moderate level, requiring extensive system security plans, configuration management plans, contingency plans, and other security documentation. Continuous monitoring becomes more intensive with monthly vulnerability scanning and more frequent reporting requirements. The investment required for Moderate typically ranges from two to three times that of Low authorization but opens access to a much larger portion of the federal market.

FedRAMP High Authorization Requirements

FedRAMP High represents the most demanding security baseline with 421 controls. These controls implement the strongest security measures such as advanced authentication mechanisms, comprehensive security monitoring with near real-time analysis capabilities, sophisticated incident response, and rigorous contingency planning with minimal recovery time objectives. The documentation requirements reach their most extensive level, with comprehensive security documentation covering all aspects of the system security posture.

Continuous monitoring at the High level requires the most vigilant oversight with more frequent assessments, immediate remediation timelines, and comprehensive reporting. The investment required for High authorization can be substantial – often 30-50% more than Moderate – but enables access to specialized federal contracts with the highest security requirements and often higher contract values.

The progression from Low to Moderate represents the most significant increase in control requirements, while the step from Moderate to High involves fewer additional controls but with substantially increased rigor in their implementation. Most organizations find the gap between Low and Moderate more challenging to bridge than the gap between Moderate and High, particularly if they’ve established mature security practices at the Moderate level.

In 2023, FedRAMP introduced an intermediate “Moderate-High” baseline with 425 controls as a transition step between Moderate and High, aimed at helping organizations incrementally adopt higher security measures. This transitional level may provide a strategic pathway for organizations planning an eventual move to High authorization.

Important Considerations When Choosing a FedRAMP Level

Several critical factors should influence your decision when selecting a FedRAMP authorization level, extending beyond the simple number of required controls.

Your target federal customer base represents perhaps the most important consideration. Federal agencies categorize their systems based on the potential impact of a security breach. If your cloud service targets agencies with predominantly Low-impact systems, pursuing Moderate authorization may not yield sufficient additional opportunities to justify the investment.

Conversely, if your primary target customers handle High-impact data, a Moderate authorization would limit your market access regardless of its broader applicability across the federal government. Research your specific customer agencies to understand their security requirements and categorization practices.

The nature of the data your cloud service will process heavily influences the appropriate authorization level. Services handling public-facing information or non-sensitive data may appropriately operate at the Low level. Services processing controlled unclassified information (CUI) such as personal information, procurement data, or routine operational information typically require Moderate.

Services handling sensitive law enforcement data, emergency services information, healthcare records, financial data, or mission-critical operational information generally require High authorization. Your service’s data profile should align with the appropriate impact level.

Your business objectives and growth strategy should guide your authorization level selection. Organizations seeking maximum federal market access might pursue Moderate as the optimal balance between investment and opportunity. Companies targeting specialized high-security niches might strategically pursue High authorization despite its greater cost to differentiate themselves in security-sensitive markets.

Those new to the federal market might select Low as an entry point with plans to upgrade later as their federal business grows. Your authorization strategy should support your broader business objectives rather than being determined solely by technical factors.

Resource constraints inevitably influence authorization decisions. If your organization lacks the financial resources, security expertise, or personnel necessary for higher authorization levels, a pragmatic approach may be to start with a lower level that aligns with your current capabilities while planning for future growth. The substantial difference in investment between levels means that realistic assessment of your organization’s capacity is essential for a successful authorization journey.

Competitive positioning within your specific market segment should also inform your decision. If most competitors in your space have achieved Moderate authorization, pursuing Low might position you at a competitive disadvantage. Conversely, achieving High authorization in a market where competitors operate at Moderate could provide a valuable differentiator. Understanding the authorization landscape in your particular segment helps inform appropriate level selection.

Technical architecture considerations may impact the feasibility of certain authorization levels. Complex multi-tenant architectures, extensive supply chain dependencies, or legacy components might present challenges for higher authorization levels. Services built using modern cloud-native approaches with security designed from the ground up may more readily achieve higher levels. A realistic assessment of your current architecture’s compatibility with various authorization levels helps avoid painful discoveries during the assessment process.

Recommendations for Choosing the Appropriate FedRAMP Level

Based on decades of experience guiding organizations through FedRAMP authorization, several recommended approaches emerge for selecting the most appropriate level for your specific situation.

For organizations new to the federal market or FedRAMP process, a graduated approach often proves most effective. Starting with Low authorization allows your organization to establish the necessary security processes, develop FedRAMP expertise, and build relationships with federal customers while making a more manageable initial investment. Once Low authorization is achieved and generating revenue, organizations can reinvest in security enhancements to pursue Moderate authorization, potentially having already addressed many of the requirements through the initial authorization process.

For established commercial cloud providers with mature security programs, directly pursuing Moderate authorization often represents the optimal strategy. The significant leap from 125 controls at Low to 325 controls at Moderate is more manageable for organizations with existing robust security practices. Given that Moderate authorization opens access to the largest segment of the federal market, the return on investment typically justifies bypassing Low altogether for organizations with sufficient resources and security maturity.

For specialized providers targeting security-sensitive federal agencies, High authorization may be the only viable option despite its greater requirements. If your target customer base primarily deals with high-impact systems, pursuing a lower authorization level would not enable market access regardless of the reduced investment. Organizations in this category should evaluate whether the specialized market opportunity justifies the substantial security investment required for High authorization.

For providers with existing FedRAMP Low authorization considering an upgrade to Moderate, conducting a gap analysis between your current security posture and Moderate requirements provides essential insight. This analysis helps quantify the additional investment required and supports a cost-benefit evaluation. Many organizations find that the expanded market access from Moderate authorization justifies the incremental investment, particularly after establishing initial revenue from Low-impact federal customers.

Organizations with existing FedRAMP Moderate authorization should carefully evaluate business cases for upgrading to High. While the control gap between Moderate and High is smaller than the gap between Low and Moderate, the implementation rigor increases substantially. Unless you have identified specific high-value opportunities requiring High authorization, most organizations find Moderate sufficient for the majority of federal business. The business case for High should demonstrate specific revenue opportunities that would become accessible only with the higher authorization level.

For organizations with substantial existing compliance achievements such as SOC 2 Type 2, ISO 27001, or CMMC, leverage your current security posture when selecting a FedRAMP level. Organizations with these certifications often find the gap to FedRAMP Moderate more manageable than organizations starting without established compliance frameworks. A crosswalk analysis between your existing controls and FedRAMP requirements can help quantify the additional effort required for various authorization levels.

Kiteworks is FedRAMP Authorized

Selecting the appropriate FedRAMP authorization level is a critical strategic decision for organizations seeking to serve the federal cloud market. This choice fundamentally shapes your investment requirements, time to market, addressable opportunities, and competitive positioning in the federal space. While the requirements become progressively more demanding from Low to Moderate to High, so too does the potential market opportunity.

A thoughtful, strategic approach to authorization level selection considers not just technical security requirements but broader business context. By aligning your authorization strategy with your federal market objectives, you can optimize your return on FedRAMP investment and position your organization for success in the federal marketplace.

Kiteworks has achieved FedRAMP Authorization for moderate impact level information, signaling that its platform meets the rigorous security standards required for federal data protection. By obtaining this authorization, Kiteworks assures government agencies and businesses that its platform can securely handle sensitive information in compliance with federal guidelines.

For government agencies, this authorization simplifies the procurement process by providing a vetted solution that meets stringent security requirements, thereby enhancing data security and compliance. For businesses, particularly those looking to work with government entities, Kiteworks’ FedRAMP Authorization provides a competitive edge, as it ensures their data handling practices align with federal expectations. This can help businesses access government contracts and partnerships, expand their market opportunities, and build trust with government clients.

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP and managed file transfer, so organizations control, protect, and track every file as it enters and exits the organization.

Organizations leveraging Kiteworks’ FedRAMP authorized services benefit from an enhanced level of security, efficiently safeguarding critical data in adherence to established compliance mandates. This ensures reliable content protection and data management.

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more. 

To learn more about Kiteworks, schedule a custom demo today. 

Additional Resources

• eBook FedRAMP Private Cloud: The Gold Standard for Sensitive Content Communications
• Blog Post Kiteworks Enterprise – Why FedRAMP Hosted vs. Standard Hosted
• Blog Post FedRAMP: The Short Path to Secure Content Communications
• Blog Post Don’t Be Fooled: Why Empty Claims of “FedRAMP Equivalency” Put CMMC Compliance at Risk
• Brief Meet the CMMC’s FedRAMP Equivalency Requirement