background

FedRAMP High: Who Needs The Highest Level & How It Compares to Moderate

  • fedrampangle-right
  • FedRAMP High: Who Needs The Highest Level & How It Compares to Moderate

FedRAMP High represents the most stringent level of security requirements under the Federal Risk and Authorization Management Program (FedRAMP). It’s designed for cloud systems that process some of the government’s most sensitive, unclassified data—where a breach could result in loss of life, mission-critical failure, or catastrophic financial harm.

In this article, we’ll cover:

  • What qualifies as a FedRAMP High system
  • What’s required to meet the High baseline
  • Key differences between FedRAMP High and FedRAMP Moderate
  • How to prepare for High authorization

What is FedRAMP High?

A FedRAMP High system is one where the loss of confidentiality, integrity, or availability would have severe or catastrophic adverse effects on an agency’s mission, assets, or individuals. Under FIPS 199, this classification applies when at least one of the three security objectives is rated as High.

  • Confidentiality: Exposure of sensitive personal data such as Social Security numbers, biometric data, or passport details could lead to identity theft or national security risks.
  • Integrity: Unauthorized changes to mission-critical data could compromise emergency response operations, financial systems, or law enforcement records.
  • Availability: Downtime or unavailability of systems supporting emergency response or healthcare could result in direct threats to life or public safety.

FedRAMP High systems are typically critical to national security and public welfare. This level of protection is essential for cloud environments that process the government’s most sensitive unclassified data. 

Let’s look at specific examples below.

Who needs FedRAMP High?

FedRAMP High is required for cloud services supporting:

  • Law enforcement systems
  • Emergency response and disaster recovery platforms
  • Healthcare systems processing medical records and life-critical data
  • Financial services systems handling sensitive taxpayer or payment data

CSPs supporting agencies such as the Department of Homeland Security, Department of Defense, Department of Justice, or the Department of Health and Human Services are likely to need FedRAMP High authorization.

This level of authorization is also becoming increasingly relevant as more agencies adopt cloud-based platforms for critical operations and as agencies elevate risk classifications of their systems.

To better understand who needs or may benefit from FedRAMP High authorization, let’s look at the CSOs that have achieved a FedRAMP designation at this level. As of July 31, 2025, there are 585 CSOs listed in the FedRAMP Marketplace. 95 are FedRAMP Authorized, FedRAMP Ready, or working toward a FedRAMP Authorization at the High level. That means high-impact systems make up about 16% of the products listed in the FedRAMP marketplace. 

Here are some examples of CSOs that have achieved a FedRAMP High designation and are listed in the marketplace:

  • Accenture Insights Platform for Government
  • AWS GovCloud
  • CrowdStrike Falcon Platform for Government
  • GovSlack
  • Google Services
  • IBM Cloud for Government
  • Microsoft Office 365 GCC High
  • Oracle Cloud Infrastructure - Government Cloud
  • Salesforce Government Cloud Plus

These CSOs have achieved a FedRAMP High designation by implementing the High baseline. Let’s take a closer look at these baseline requirements below.

FedRAMP High baseline: What’s required?

FedRAMP High requires the implementation of 410 security controls from the NIST SP 800-53 Rev. 5 control catalog. These controls span 17 control families and represent the highest degree of security assurance under the FedRAMP program.

Here’s a breakdown of how those 410 controls are distributed across the 17 control families and how those allocations compare to the other traditional Moderate and Low baselines:

The FedRAMP High baseline places significant emphasis on:

  • Access Control (50 controls)
  • Contingency Planning (35 controls)
  • System and Communications Protection (35 controls)
  • System and Information Integrity (35 controls)

These areas highlight the critical nature of High-impact systems, with strong requirements for ensuring resilience, protecting system access, and responding swiftly to incidents.

FedRAMP High vs FedRAMP Moderate: Key differences

While both FedRAMP High and Moderate require rigorous controls and federal agency sponsorship, they differ significantly in scope, intent, and operational requirements. Below are the core areas where the two diverge—and what you should consider when deciding which impact level applies to your cloud service offering.

Control Count

One of the most immediate and measurable differences is the number of required controls. The FedRAMP Moderate baseline includes 323 security controls, while FedRAMP High includes 410. 

The additional 87 controls in the FedRAMP High baseline span nearly every control family, with particular increases in contingency planning, auditing, and system integrity. This increase is designed to provide additional assurance around data integrity, availability, and confidentiality, particularly for mission-critical systems.

Data Sensitivity

Moderate-impact systems typically handle Controlled Unclassified Information (CUI) or sensitive-but-unclassified data. High-impact systems, on the other hand, manage data that—if compromised—could lead to national security threats, major financial harm, or even loss of life. The nature of the data dictates the additional level of scrutiny required.

Use Cases

FedRAMP Moderate covers a wide range of use cases such as CRM platforms, financial systems, and HR applications.

FedRAMP High is typically reserved for cloud services supporting law enforcement, emergency management, defense systems, and healthcare platforms where system failure could have catastrophic consequences.

FedRAMP Marketplace share

The current FedRAMP Marketplace (as of July 31, 2025) lists 519 moderate- and high-impact systems out of a total of 585 CSOs that have achieved a FedRAMP designation. 

Since 424 of these are moderate-impact systems, FedRAMP Moderate represents the majority (73%) of the products listed in the FedRAMP marketplace. 95 of the CSOs listed in the FedRAMP Marketplace are high-impact, which means FedRAMP High represents 16% of the products listed in the marketplace. This makes sense considering that FedRAMP High is reserved for CSOs that present the highest risk to federal agencies. 

To help you determine which baseline aligns best with your organization’s risk profile and federal customer requirements, here is a summary of the key differences between FedRAMP Moderate and High:

FedRAMP High increases both the quantity and depth of security controls compared to Moderate. The authorization process is also more complex and time-consuming, requiring rigorous documentation, testing, and ongoing compliance oversight.

Choose FedRAMP High if:

  • Your CSO supports national security or law enforcement functions
  • Your system handles data classified as High under FIPS 199
  • A federal agency specifically requires High-level authorization

FedRAMP Baselines Control Allocation Spreadsheet

To get a sense of how comprehensive the High baseline is compared to other baselines and to the different areas of cybersecurity represented by each control family, we've broken down the number of controls per family across the FedRAMP Low, Li-SaaS, Moderate, and High baselines.

How to prepare for FedRAMP High authorization

Preparing for FedRAMP High is a major undertaking. CSPs should approach it with clear expectations, sufficient resourcing, and close coordination with their sponsoring agency. 

The steps below are based on 7.1 Phase 1: Preparation of the latest FedRAMP® CSP Authorization Playbook.

Step 1: Partner with federal agency

FedRAMP currently allows only one path to authorization: through a federal agency sponsor. This means that a CSP must first establish a relationship with a federal agency willing to sponsor their authorization effort. This could be an existing customer using an on-premise version of your service, an agency already adopting your solution, or a new opportunity identified through an RFP or government contract.

Step 2: Allocate resources to High authorization process

At a minimum, CSPs should dedicate:

  • A technical writer to manage documentation
  • A technical subject matter expert (SME) to explain system configurations and security controls
  • A project manager to coordinate milestones and communication

Since FedRAMP High requires a substantial resource commitment, additional engineering, product, and compliance resources may be needed, particularly if your cloud service offering (CSO) is complex.

Step 3: Select a 3PAO for the assessment.

All FedRAMP Low authorizations require a security assessment conducted by a Third Party Assessment Organization (3PAO). CSPs must choose a 3PAO listed in the FedRAMP Marketplace to ensure the assessor meets the necessary quality, independence, and FedRAMP knowledge requirements.

Step 4: Complete FedRAMP training for CSPs.

FedRAMP creates training to help stakeholders obtain the knowledge and skills necessary to successfully navigate the FedRAMP process and meet its requirements. 

While optional, the courses for CSPs are designed to help them understand the requirements of security package development and provide a detailed overview of the required templates and supporting documentation. There are five courses in total:

  • 200-A: FedRAMP System Security Plan (SSP) Required Documents 
  • 200-B: Security Assessment Plan (SAP)
  • 200-C: Security Assessment Report (SAR)
  • 200-D: Continuous Monitoring Overview
  • 201-B: How to Write a Control

FedRAMP recommends reviewing the training materials for third-party assessors and federal agencies as well.

Training is available via pre-recorded sessions on the FedRAMP YouTube channel or through live virtual sessions.

Step 5: Determine your sponsoring agency’s review approach

There are two approaches the federal agency you’ve partnered with may take when reviewing your authorization package. Knowing their approach will help you build out your roadmap and determine which documents to prioritize. 

The two review approaches are:

  • Just-In-Time Linear Approach: Each deliverable—the Security System Plan (SSP), Security Assessment Plan (SAP), and Security Assessment Report (SAR)—is submitted and reviewed in a linear fashion, with agency feedback incorporated in each deliverable before moving to the next. This is the recommended method by FedRAMP, as it enables more agile collaboration and avoids costly rework after 3PAO testing has occurred.
  • All Deliverables Provided Simultaneously: All key deliverables are submitted at once and reviewed together. This approach can work for teams with more resources but may introduce delays if significant changes are needed.

Step 6: Have a kick off meeting

The final step in this phase is to prepare for and conduct a kickoff meeting with your team, 3PAO, and federal agency sponsor. The purpose of the kickoff meeting is to formally begin the FedRAMP agency authorization process by introducing key team members, reviewing the CSO, and making sure everyone is aligned on the overall process and milestone timelines. At the conclusion of the kickoff meeting, all stakeholders will have a shared understanding of:

  • The overall authorization process, milestones, deliverables, roles and responsibilities, and schedule
  • The CSO’s purpose and function, authorization boundary, data flows, known security gaps and plans for remediation, federal agency-specific requirements, customer responsible controls, and areas that may require federal agency risk acceptance
  • The federal agency’s process for reviewing the authorization package and reaching a risk-based authorization decision
  • Best practices and tips for success

The role of automation in simplifying FedRAMP High authorization

Preparing for FedRAMP High requires a substantial commitment of time, expertise, and resources. With 410 required controls, extensive documentation, and the most rigorous assessment and continuous monitoring expectations, CSPs must be highly organized and proactive.

Starting early, aligning closely with your sponsoring agency, and following the phased guidance in the FedRAMP CSP Authorization Playbook can make the process more manageable. But even with clear steps in place, manual preparation can be overwhelming.

That’s why many organizations turn to compliance automation platforms like Secureframe to accelerate FedRAMP readiness. By streamlining control mapping, SSP creation and other documentation, evidence collection, and POA&M tracking and driving your continuous monitoring strategy with automated tests and deep cloud integrations, Secureframe helps CSPs reduce time-to-ATO and maintain compliance over time, even for this most stringent baseline. 

Whether you’re supporting national security, defense, or high-impact civilian use cases, FedRAMP High authorization is the key to unlocking the most sensitive federal workloads. With the right preparation and tools, it’s an achievable milestone that builds trust with federal partners and strengthens your cloud security program.