08 March 2024

Insights into DoD's New FedRAMP Moderate Equivalency Guidelines for Cloud Providers

Navigating the FedRAMP Equivalency Memo and DoD Regulations

Kalid Tarapolsi
Kalid Tarapolsi Chief Growth Officer LinkedIn

A memorandum has recently been circulated among top officials within the Pentagon and Department of Defense (DoD) departments (as well as industry stakeholders), outlining updated FedRAMP Moderate Equivalency instructions for Cloud Service Providers (CSPs) and their Cloud Service Offerings (CSOs). This important directive aims to enhance the security of cloud services that process defense-related data, emphasizing the critical role of cybersecurity in protecting controlled unclassified information (CUI) and aligning with DFARS 7012 requirements.

In-depth Analysis of FedRAMP Moderate Equivalency

FedRAMP is an important framework for standardized security assessment, authorization, and continuous monitoring of cloud products and services used by U.S. federal agencies. The introduction of the Moderate Equivalency guidance underscores the standards CSPs must meet when dealing with defense information, according to the Defense Federal Acquisition Regulations Supplement (DFARS). This guidance permits CSPs to demonstrate compliance with the FedRAMP moderate security baseline through evaluation by a certified Third Party Assessment Organization (3PAO). This distinct path emphasizes a tailored approach to meeting key security requirements, reinforcing the defenses against potential cybersecurity threats and aligning with national security goals. This is a departure from the previous approach which allowed self-attesting of meeting FedRAMP equivalent level of controls and now requires the use of a 3PAO to validate alignment with FedRAMP Moderate security controls.

Detailed Documentation for Ensuring Compliance

The memorandum specifies a comprehensive suite of documents and plans that CSPs are required to create and maintain to substantiate their compliance with the FedRAMP Moderate framework. This documentation includes:

  • System Security Plan (SSP): An exhaustive documentation outlining the security measures and controls in place for a cloud service.

  • Security Policies and Procedures: Detailed descriptions of the security protocols and practices adopted by the CSP to protect sensitive information.

  • User Guide and Digital Identity Verification: Instructions and protocols for user access and identity authentication.

  • Rules of Behavior and Information System Contingency Plan: Guidelines for user conduct and emergency response plans for information system disruptions.

  • Incident Response and Configuration Management Plans: Strategies for responding to security incidents and managing system configurations to prevent unauthorized access.

  • Security Assessment and Penetration Testing Plans: Methodologies for evaluating the security posture of cloud services and identifying vulnerabilities (draft FedRAMP Pen Testing Guidance can be found here).

  • Reports on Security Assessment and Action Plans: Documentation of security evaluations and remediation strategies, highlighting a proactive approach to managing security risks.

  • Strategies for Continuous Monitoring and Executive Summaries: Frameworks for ongoing surveillance of security controls and concise reports for executive oversight.

This body of evidence is important for CSPs to document their adherence to security standards and demonstrates a culture of transparency and accountability in cloud security.

Expanded Implications and Opportunities for CSPs

The issuance of this memo extends beyond just guidelines; it establishes a strategic framework for CSPs aiming to enhance and solidify their market position within the defense sector. Attaining FedRAMP Moderate Equivalency is not only a regulatory milestone; it demonstrates a CSP’s commitment to safeguarding sensitive defense information. This distinction is particularly important as the digital landscape evolves, with increased threats and more sophisticated cyber-attacks becoming more prevalent.

The journey toward compliance is comprehensive and challenging. It necessitates a thorough understanding of intricate security controls, meticulous documentation, and robust continuous monitoring mechanisms. CSPs are urged to promptly address any deficiencies unearthed during the 3PAO assessment process, ensuring there are no lingering security gaps or unmet benchmarks.

Strategic Relevance for Cloud Service Providers

The updated guidance symbolizes a significant strategic shift towards advanced cybersecurity measures and uniformity among CSPs serving the federal civilian and defense sectors. This move not only signifies the DoD’s dedication to securing defense data but also sets an elevated expectation for CSPs to enhance their security protocols. For CSPs, this is an invaluable opportunity to differentiate themselves in a competitive landscape. Meeting the FedRAMP Moderate Equivalency standards not only facilitates entry into defense contracting, but also reassures their client base of the provider’s commitment to cybersecurity standards.

Additionally, this guidance serves as a reminder for CSPs about the nature of the cybersecurity field and the escalating requirements to deliver secure, robust, and compliant cloud solutions. As the DoD continues to refine its cybersecurity mandates, it’s important for CSPs to remain flexible, continuously augmenting their security frameworks to align with or exceed these evolving standards.

The Critical Role of Expert Advisory Partners in Navigating FedRAMP and DoD Compliance Landscapes

Navigating the complexities of FedRAMP and Department of Defense (DoD) compliance requires not just a deep understanding of the technical standards but also a nuanced grasp of the regulatory and strategic landscapes. This is where the role of a strong advisory partner becomes invaluable.

A proficient advisory partner brings a wealth of experience and expertise in both the FedRAMP framework and DoD requirements, ensuring that Cloud Service Providers (CSPs) navigate these regulatory waters efficiently and effectively. Such partners understand the nuances of the security measures, documentation, and processes required for compliance. They can guide CSPs through the labyrinth of regulations, helping them avoid common pitfalls and streamline the compliance process. This expertise is crucial not only for achieving initial compliance but also for maintaining it through continuous monitoring and updates in response to evolving threats and changing regulations.

Navigating FedRAMP and DoD landscapes involves interacting with multiple stakeholders, including third-party assessment organizations (3PAOs), the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC), and various DoD entities. A strong advisory partner can facilitate effective engagement and communication with these stakeholders. They can help CSPs articulate their security measures and compliance status more effectively, thereby building trust and credibility with the DoD and other partners.

Each CSP’s situation is unique, with different technologies, business models, and risk profiles. A knowledgeable advisory partner can provide tailored solutions that fit the specific needs of a CSP, rather than a one-size-fits-all approach. They can also guide CSPs in implementing best practices and innovative security technologies, ensuring that their cloud services not only meet current compliance standards but are also positioned for future developments. This approach shows that CSPs remain agile and can adapt to new threats and regulatory changes, maintaining their compliance and security posture over time.

A strong advisory partnership is not just transactional but a long-term relationship that grows and evolves with the CSP’s business. Such partners can play a crucial role in educating and training CSP staff on compliance, security, and regulatory changes, building a culture of continuous improvement and compliance within the organization.


The enhanced FedRAMP Moderate Equivalency guidelines for CSPs signify a critical step forward, accentuating the role of robust cybersecurity within the defense sector’s cloud computing strategy. By delineating explicit compliance pathways and expectations, the DoD is integrating CSPs as strategic allies in the mission to safeguard national security information. For CSPs, the directive is unequivocal: achieving and upholding compliance goes beyond just accessing the defense market; it’s about demonstrating cybersecurity excellence across verticals. This commitment not only supports national security objectives but also propels the CSPs to the forefront of cybersecurity leadership in the marketplace.

For additional information on the topic, check out this recent interview with industry leader Jacob Horne with Aquia’s President and Co-Founder Chris Hughes.

If you are interested in learning more or scheduling a consultation to discuss pursuing your FedRAMP authorization, contact us. Backed by a former FedRAMP Joint Authorization Board (JAB) technical representative member, our team understands the nuances, expectations, and critical success factors that can make all the difference when it comes to achieving authorization and scaling within the federal government and DoD.

Looking to learn more about accelerating your FedRAMP journey and expanding your presence within the federal government and DoD? Check out recordings from our Aquia + AWS 2024 Cloud Compliance Summit, a one-day event focused on FedRAMP.

If you have any questions, or would like to discuss this topic in more detail, feel free to contact us and we would be happy to schedule some time to chat about how Aquia can help you and your organization.