Table Of Contents
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Re-thinking FedRAMP: Security Over Compliance
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Controls vs. KSIs: What's Actually Changing
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Out with Controls, In with the KSIs
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This Doesn’t Feel Like Compliance Anymore
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Templates and Formats For Existing Infrastructure
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Low vs Moderate
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But I Already Have Rev 5 With The Controls!
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I Have Thoughts–How Can I Weigh In?
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Conclusion
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Preparing for FedRAMP 20X?
This one’s for the nerds, the engineers, the compliance pros who actually read the GitHub commits and know what the acronyms mean (don’t worry I’ll still explain them the first time).
FedRAMP20X is coming, and it’s not just a revision: It’s a re-architecture. Not only that, but we fully expect it to replace Rev 5 Legacy FedRAMP entirely. Here’s what’s changing under the hood, and what it means for the people who actually have to implement it.
Re-thinking FedRAMP: Security Over Compliance
FedRAMP 20X represents a shift from proving compliance on paper to proving security in real time. Today, FedRAMP is built around controls, assessments, and documentation. Tomorrow, it will center on machine-readable data, automation, and continuous validation.
Learn more: FedRAMP 20X Pilot in Plain English: What’s New, What’s Next, and Why It Matters
Controls vs. KSIs: What’s Actually Changing
Legacy FedRAMP (Rev 5) is built around controls: static requirements you describe and prove through documentation and a yearly assessment. Each control defines a behavior or safeguard (like “implement multi-factor authentication”) and requires written evidence to show compliance.
FedRAMP 20X replaces that model with Key Security Indicators (KSIs): measurable security signals that continuously demonstrate whether a safeguard is working.
In other words:
- Controls are descriptive: You write about what’s in place.
- KSIs are demonstrative: The system itself reports whether it’s working.
This shift moves FedRAMP from periodic, human-reviewed compliance to continuous, machine-validated security.
Or, more simply:
- In the old model, you proved compliance once a year.
- In the 20X model, your system proves it every day.
Ready to explore FedRAMP for your product? Learn what it takes.
Out with Controls, In with the KSIs
FedRAMP20X will have a host of Key Security Indicators:
- Low-impact systems: 51 KSIs
- Moderate: 59 KSIs
- High: To be announced
These KSIs define your system’s security profile and are automatically reported in machine-readable format through trust centers. When a KSI drifts out of compliance, remediation can (and should) happen immediately: no more waiting for the next annual assessment.
This Doesn’t Feel Like Compliance Anymore
It is still a compliance framework, but it is time to re-think the philosophy behind it. Instead of checking off controls and writing long descriptions, the system will validate the KSIs for you and send the information in machine-readable formats. It is going to be a lot faster and a lot more autonomous than the existing system. Think: Less audit binder, more real-time telemetry.
Templates and Formats For Existing Infrastructure
You’ll be able to reuse your existing policies (formatted to FedRAMP templates) to validate KSIs. Evidence can be submitted in a machine-readable format instead of narrative. That’s a big shift toward automation and away from paperwork.
Low vs Moderate
The real jump from 20X Low to 20X Moderate isn’t the number of KSIs: It’s how they’re validated.
For Low, self-attestation is enough. For Moderate, validation must be automated and opinionated. It’s a tighter, smarter, more data-driven model. In short, Low trusts your word; Moderate trusts your data.
But I Already Have Rev 5 With The Controls!
Good news: Your work isn’t wasted. FedRAMP is publishing mappings between existing Rev 5 controls and 20X KSIs. Controls still matter–they just feed into an automated validation model instead of a written report.
Machine-readable data will now tell the story your documentation used to. If you’ve built a solid control environment, you’re already halfway to 20X compliance, and 38North can help you bridge the rest.
I Have Thoughts–How Can I Weigh In?
Great question! The FedRAMP Office has made 20X unusually transparent. You can review the draft KSIs and share feedback directly through the FedRAMP 20X Community GitHub here.
Conclusion
FedRAMP 20X isn’t an update: It’s a re-architecture. Controls now map to KSIs, validated and reported automatically in real time.
Paper reports and periodic audits are being replaced by continuous validation. It’s still a compliance framework, but one that finally behaves like security.
Preparing for FedRAMP 20X?
Whether you’re planning your first authorization or adapting from Rev5, 38North Security can help you align your controls, automate validation, and stay ahead of the curve. Get in touch with our team today.
Table Of Contents
-
Re-thinking FedRAMP: Security Over Compliance
-
Controls vs. KSIs: What's Actually Changing
-
Out with Controls, In with the KSIs
-
This Doesn’t Feel Like Compliance Anymore
-
Templates and Formats For Existing Infrastructure
-
Low vs Moderate
-
But I Already Have Rev 5 With The Controls!
-
I Have Thoughts–How Can I Weigh In?
-
Conclusion
-
Preparing for FedRAMP 20X?
