Historical Reference Only
RFC-0020 is closed and its content is retained for historical reference only. Do not reference or implement any aspect of this content for active compliance planning. Monitor fedramp.gov/rfcs for finalized guidance.
FedRAMP Certified vs. Validated: Understanding the Proposed 2026 Designations
RFC-0020 proposed replacing "FedRAMP Authorized" with two distinct labels. The comment period ran January 13 – February 19, 2026. This page documents what was proposed for historical and educational reference.
Why Was This Proposed?
The FedRAMP Board identified that "FedRAMP Authorized" created three dangerous misconceptions across the ecosystem:
CSPs treating a FedRAMP authorization as a government-wide ATO — it is not.
Federal employees using FedRAMP authorized services without agency oversight or review.
Agency security officials skipping their own ATO process, assuming FedRAMP or other agencies cover their risk.
⚠️ FedRAMP Ready retirement was also proposed under this RFC.
Proposed Rev5 Path
Would indicate a point-in-time assessment based primarily on review of filed paperwork against legacy Rev5 requirements.
Proposed 20x Path
Would indicate persistent validation — the provider demonstrates their security posture continuously such that their package always reflects current status.
Proposed: FedRAMP Certified Levels (Rev5)
Minimum information — adequate for negligible or low risk non-sensitive decisions in most cases.
Small amount of information — adequate for low impact authorization decisions in most cases.
Typical amount of information — adequate for moderate impact decisions in most cases.
Typical information adequate for moderate impact in almost every case. All Rev5 BIRs implemented, no corrective action for 1 year.
Significant information — adequate for high impact authorization decisions in many cases.
Significant information adequate for high impact in almost every case. All Rev5 BIRs implemented, no corrective action for 1 year.
Proposed: FedRAMP Validated Levels (20x)
Minimum information — adequate for negligible or low risk non-sensitive decisions in most cases.
Small amount of information — adequate for low impact authorization decisions in most cases.
Typical amount of information — adequate for moderate impact decisions in most cases.
Typical information adequate for moderate impact in almost every case. Nearly all FedRAMP recommendations met, no corrective action for 1 year.
Significant information — adequate for high impact authorization decisions in many cases.
Significant information adequate for high impact in almost every case. Nearly all FedRAMP recommendations met, no corrective action for 1 year.
Auditor's Perspective
Independent commentary — not official FedRAMP guidance
"In my consulting work, I tell clients that 'Validated' is a marketing badge as much as a security one. Agencies are being incentivized to pick Validated services because the Agency ATO process is significantly automated when the underlying data is already in OSCAL format. The practical effect is that a Validated Level 3 CSP will move through multi-agency adoption faster than a Certified Level 3 CSP — not because they're more secure, but because their evidence is machine-readable and always current."
What This Proposed Framework Signals
Even as a closed RFC, the direction is informative for planning purposes.
Currently Rev5 Authorized
The RFC proposed automatic remapping to a Certified level. Watch for finalized guidance from FedRAMP on whether this proceeds.
Currently in 20x Pilot
The direction of travel strongly favors persistent validation. Continue 20x track regardless of RFC outcome.
Currently FedRAMP Ready
FedRAMP Ready retirement was proposed. Even if this specific RFC doesn't finalize, treat Ready as a transitional status and plan your next step.
Not Yet in FedRAMP
New entrants should strongly consider the 20x path. The Certified path has no public roadmap beyond 2027 regardless of this RFC's outcome.
Sources
RFC-0020 opened January 13, 2026 and closed February 19, 2026. Content retained for historical and educational reference only. Last reviewed February 22, 2026.