FedRAMP 20x has quickly become one of the most talked-about developments in the federal cloud ecosystem.
One of the most common questions we hear from cloud providers and security leaders is simple: Will FedRAMP 20x actually be easier than Rev. 5?
In this first episode of our FedRAMP 20x series, Ingrid Woodley (Senior Director of Revenue Strategy at 38North Security) is joined by Matt Earley (Founder and President) and Sam Leestma (VP of Solutions Engineering) to unpack the realities behind the FedRAMP 20x transition.
The conversation explores:
- Why the “20x will be easier” narrative is misleading
- What actually becomes simpler under the new model
- Where the work becomes more demanding
- How continuous validation changes the operational expectations for cloud providers
Watch the full discussion below:
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FedRAMP 20x has generated a lot of excitement across the federal cloud ecosystem.
One of the most common questions we hear from customers and partners is simple:
“Is FedRAMP 20x actually going to be easier than FedRAMP Rev. 5?”
At first glance, the answer might seem like yes.
FedRAMP 20x promises a significant reduction in static documentation. It shifts away from point-in-time assessments and toward continuous validation. And it emphasizes automation and machine-readable evidence instead of large documentation packages.
But the reality is more nuanced.
Let’s explore what’s really changing, and why the question of whether 20x is “easier” depends heavily on how an organization is built and operated today.
FedRAMP 20x: Why the “Easier” Narrative Exists
The perception that FedRAMP 20x will be easier largely comes from the most visible changes to the program.
Under the traditional model, cloud service providers must produce extensive documentation and evidence packages to demonstrate compliance with FedRAMP requirements. These assessments occur at defined intervals and require significant manual effort from both providers and assessors.
FedRAMP 20x aims to modernize that process.
Learn more: FedRAMP 20x: A Primer for Executives
Instead of relying on large documentation packages and scheduled assessments, the new model focuses on continuous validation. Systems generate machine-readable security data that demonstrates whether safeguards are functioning within defined tolerances.
This shift reduces the need for extensive written narratives and manual evidence collection.
However, reducing paperwork does not necessarily reduce the work required to operate securely.
Less Paperwork Doesn’t Mean Less Work
As Sam Leestma, Vice President of Solutions Engineering at 38North Security and former FedRAMP PMO contributor, explains, the work simply moves to a different place.
Instead of assembling documentation for periodic audits, organizations must design systems that can continuously demonstrate security outcomes.
That means engineering environments that:
- Capture security telemetry in real time
- Structure security signals in machine-readable formats
- Automatically report whether critical safeguards remain within expected tolerances
In other words, security must be observable through automation rather than explained through documentation.
This approach eliminates much of the “audit theater” that compliance teams have traditionally experienced: where humans interpret machine output, write narratives about it, and pass those narratives to other humans for review.
But it also requires a higher degree of engineering discipline and operational maturity.
Cloud service providers must be able to detect issues quickly, assess their impact, and respond within defined timelines, all while continuously demonstrating the health of their systems.
The Work Moves Earlier in the Process
Matt Earley, founder and president of 38North Security, highlights another important dynamic.
While the overall timeline for authorization may become shorter, organizations should expect a meaningful upfront engineering investment to prepare for the continuous validation model.
To support FedRAMP 20x, providers must implement capabilities such as:
- Modern development and CI/CD practices
- Structured telemetry pipelines
- Automated evidence generation
- Real-time reporting of security signals
These capabilities allow systems to produce the machine-readable outputs that continuous validation requires.
For organizations already operating with strong automation and cloud-native engineering practices, the shift may feel natural.
For others, it represents a significant architectural and operational change.
A Shift Driven by the Buyer
Another key theme in the episode is that FedRAMP 20x is not primarily about making compliance easier for cloud providers.
It’s about enabling federal agencies to move faster.
Government buyers increasingly rely on cloud technologies to support mission delivery. Long procurement timelines and static compliance models can slow the adoption of modern tools.
By moving toward continuous validation, FedRAMP 20x aims to provide agencies with faster visibility into the security posture of cloud systems, allowing them to adopt technology more quickly while maintaining strong security assurances.
In other words, FedRAMP 20x makes it easier for the federal government to adopt commercial versions of software instead of relying on government-specific variants that often lag behind the pace of commercial innovation.
For cloud providers, this shift creates both opportunity and pressure.
Organizations that can demonstrate continuous security effectively may gain a competitive advantage in the federal marketplace.
At the same time, increased transparency may also introduce reputational considerations. If continuous security signals become visible to government buyers—or even publicly available—security posture could become a differentiator not only for compliance but also for market credibility.
A Different Question Leaders Should Ask
Given these dynamics, the question “Is FedRAMP 20x easier?” may not be the most useful way to frame the transition.
Instead, leaders should consider a different set of questions:
- Are our systems engineered to be observable?
- Can we continuously demonstrate security posture through automation?
- Do our operational processes support real-time detection and response?
- Can we sustain security performance under continuous scrutiny?
These questions move the conversation away from documentation requirements and toward operational resilience.
Learn more: Is FedRAMP 20x “More Secure” Than FedRAMP Rev. 5?
What’s Next in the Series
In the next episode, we’ll explore what tends to break first when organizations move toward continuous validation, and how teams can prepare without overengineering their environments.
If you’re evaluating FedRAMP 20x or planning your federal market strategy, understanding these shifts early can help you design systems and processes that align with where the program is heading. Get in touch with our team today.
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