This FedRAMP Authorization Readiness Checklist provides IT and Security teams with a concrete, verifiable framework to assess organizational preparedness for FedRAMP authorization. Each item maps to specific FedRAMP requirements and NIST standards to ensure compliance across security controls, documentation, and operational readiness. Use this checklist to identify gaps, track remediation efforts, and demonstrate compliance to FedRAMP assessors.
FedRAMP Authorization Readiness Checklist
- Security Assessment Plan (SAP) Complete: Develop and finalize a comprehensive SAP documenting all NIST SP 800-53 controls applicable to your system. Reference: FedRAMP Program Management Office (PMO) SAP Template and NIST SP 800-53A assessment procedures.
- System Security Plan (SSP) Documented: Create a detailed SSP covering system boundaries, architecture, data flows, and control implementations for all required controls. Reference: FedRAMP SSP Template and NIST SP 800-53 control documentation requirements.
- Control Implementation Evidence Collected: Gather documented evidence (screenshots, policies, logs, configurations) for each implemented control across all control families (AC, AU, AT, CA, CM, etc.). Reference: NIST SP 800-53A assessment procedures and FedRAMP Continuous Monitoring Strategy.
- Risk Assessment Completed: Conduct a formal risk assessment identifying threats, vulnerabilities, likelihood, and impact for all system components and data. Reference: NIST SP 800-30 Risk Assessment Guide and FedRAMP security categorization requirements.
- System Security Categorization Validated: Confirm FIPS 199 categorization (Low, Moderate, High) for confidentiality, integrity, and availability based on data sensitivity and mission criticality. Reference: FIPS 199 and FedRAMP baseline control requirements.
- Access Control Matrix Established: Document role-based access control (RBAC) and user access privileges with quarterly review evidence for all system users. Reference: NIST SP 800-53 AC-2 (Account Management) and AC-6 (Least Privilege).
- Audit Logging and Monitoring Enabled: Verify all systems generate, retain, and review audit logs for security-relevant events with centralized monitoring configured. Reference: NIST SP 800-53 AU-2 (Audit Events), AU-6 (Audit Review), and AU-12 (Audit Generation).
- Incident Response Plan Documented and Tested: Develop incident response procedures including detection, reporting, containment, and recovery with evidence of at least one annual drill. Reference: NIST SP 800-53 IR-1 (Incident Response Policy) and NIST SP 800-61 Computer Security Incident Handling Guide.
- Configuration Management and Baselines Established: Document system baselines, change control procedures, and maintain a Configuration Management Database (CMDB) with change logs. Reference: NIST SP 800-53 CM-2 (Baseline Configuration) and CM-3 (Change Control).
- Vulnerability Management Program Operational: Implement regular vulnerability scanning, penetration testing, and documented remediation plans with SLA timelines. Reference: NIST SP 800-53 RA-5 (Vulnerability Scanning) and FedRAMP Continuous Monitoring requirements.
- Continuous Monitoring Plan Established: Create and implement a monitoring strategy with defined metrics, tools, frequency, and escalation procedures for ongoing compliance verification. Reference: FedRAMP Continuous Monitoring Strategy Guide and NIST SP 800-53A monitoring procedures.
- Security Training and Awareness Program Active: Verify all personnel complete annual security awareness training and role-specific training with completion documentation and assessments. Reference: NIST SP 800-53 AT-1 (Security Awareness and Training Policy) and AT-2 (Security Awareness Training).
- Backup and Disaster Recovery Tested: Document backup procedures, recovery time objectives (RTO), recovery point objectives (RPO), and evidence of successful recovery testing within past 12 months. Reference: NIST SP 800-53 CP-4 (Contingency Plan Testing) and CP-9 (Information System Backup).
- Encryption Standards Implemented: Confirm encryption in transit (TLS 1.2+) and at rest (FIPS 140-2 validated cryptography) for all sensitive data with key management procedures documented. Reference: NIST SP 800-53 SC-7 (Boundary Protection), SC-13 (Cryptographic Protection), and FIPS 140-2.
- Privileged Access Management (PAM) Implemented: Deploy multi-factor authentication (MFA) for privileged accounts with session recording and just-in-time (JIT) access provisioning. Reference: NIST SP 800-53 IA-2 (Authentication), AC-3 (Access Enforcement), and FedRAMP MFA requirements.
- System and Information Integrity Verification Active: Implement file integrity monitoring (FIM), security information and event management (SIEM), and intrusion detection systems (IDS) with alert procedures. Reference: NIST SP 800-53 SI-7 (Software, Firmware, and Information Integrity) and CA-7 (Continuous Monitoring).
- Third-Party/Contractor Assessment Completed: Assess all third-party services and contractors for compliance with FedRAMP requirements and document service-level agreements (SLAs) and data handling agreements. Reference: NIST SP 800-53 SA-9 (External Information System Services) and FedRAMP Third-Party Assessment guidance.
- Privacy Impact Assessment (PIA) and Data Handling Procedures Documented: Complete a PIA for all personally identifiable information (PII) and establish data minimization, retention, and disposal procedures. Reference: NIST SP 800-122 Guide to Protecting the Confidentiality of PII and OMB guidance on Privacy Impact Assessments.