Understanding the New FedRAMP Labels
Imagine you're in a procurement meeting, and someone questions whether a cloud service labeled "FedRAMP Moderate" is now "Class C" or if the baseline has changed entirely. Your contracting officer wonders if the new "FedRAMP Certification" label differs from the old "FedRAMP Authorization." Meanwhile, your ISSO is concerned about reassessing services with an existing FedRAMP package.
These aren't hypothetical scenarios. Since FedRAMP published the initial outcome from RFC-0020 on February 25, 2026, these questions have been frequent. The program's labeling overhaul is the most significant since the FedRAMP Authorization Act, impacting how you interpret authorizations, draft procurement language, and explain risk decisions to leadership.
Here's what you need to know.
Q1: Is It "FedRAMP Certification" or "FedRAMP Authorization"?
It's now FedRAMP Certification. This is the official label for all FedRAMP authorizations, aligning with the FedRAMP Authorization Act, which defines an authorization as "a certification that a cloud computing product or service has completed a FedRAMP authorization process."
For your contracts and RFPs: Use "FedRAMP Certification" in new documents. You don't need to amend existing contracts that mention "FedRAMP Authorization," but start using the new term in procurement language after the FedRAMP Consolidated Rules for 2026 (CR26) are published by June 2026.
Q2: Does a FedRAMP Certification Meet Statutory Requirements?
Yes. A FedRAMP Certification is equivalent to a FedRAMP authorization for statutory or regulatory requirements, including agency authorization for cloud services within federal information systems.
The label has changed, but the authority hasn't. If your agency policy requires "a FedRAMP authorization," a FedRAMP Certification fulfills that requirement. Update your compliance checklists with the new terminology, but don't add new approval gates.
Q3: What Happened to "FedRAMP Validated" for 20x Services?
FedRAMP has eliminated the "FedRAMP Validated" designation based on public feedback. There won't be separate labels for different assessment methodologies like 20x and Rev5 paths. Instead, FedRAMP will offer marketplace filters to differentiate these paths. Both will carry the "FedRAMP Certification" label.
For your team: Focus on the baseline class and actual controls in the certification package, not on "Validated" vs. "Certified."
Q4: What Are the "Class A, B, C, D" Labels?
FedRAMP is replacing the Low/Moderate/High baseline labels with a Certification Class system (A, B, C, or D) to avoid confusion with the DoD Impact Level system.
Here's the mapping for Rev5:
- Class A: New pilot baseline
- Class B: Current Li-SaaS and Low baselines
- Class C: Current Moderate baseline
- Class D: Current High baseline
The 20x requirements will align with these Rev5 classes in CR26.
Critical point: The class defines the scope of the assessment and certification by FedRAMP, not the overall security of the cloud service. This distinction is crucial for your authorization decisions.
Q5: Did the Requirements Change for Each Baseline?
No. The baselines themselves have only minor changes. FedRAMP isn't altering requirements, just providing labels that better align with its responsibility and authority.
There was confusion during the RFC comment period, but a service certified at Class C still meets the same control set as the current Moderate baseline.
For your authorization packages: You don't need to reassess services or request updated packages due to the label change. The controls remain the same.
Q6: Can I Use a Class C Certification for a High System?
Yes, if your agency accepts the risk. OMB Memorandum M-24-15 and FedRAMP policies encourage using a FedRAMP Certification at different security categories than the certification itself.
A FedRAMP Certification isn't a guarantee that a cloud service meets all requirements for a specific FIPS 199 security category. Agencies can use a FedRAMP Certification Package to authorize a cloud service in an agency information system at any security category deemed appropriate, following the Risk Management Framework.
The class label indicates the depth and complexity of information provided by the cloud service provider, not the overall security of your system. Conduct your own risk assessment, document residual risks, and get your authorizing official's signature.
Q7: What's the Transition Timeline for the New Labels?
FedRAMP will publish the FedRAMP Consolidated Rules for 2026 by June 2026, valid until December 31, 2028.
During the transition, old and new labels will be linked. Expect both "Moderate" and "Class C" to be used interchangeably while the marketplace updates.
For your documentation: Start using the class system in procurement language, but include a parenthetical reference to the old label for clarity during the transition: "FedRAMP Certification at Class C (Moderate baseline)."
Q8: Will There Be Additional Certification Levels?
No. FedRAMP won't create additional certification baselines based on corrective actions or recommendations in CR26.
FedRAMP will share information about optional processes and corrective actions with agencies via the FedRAMP Marketplace. This information will be available when reviewing a certification package, but it won't result in a separate certification tier.
For your evaluation criteria: Don't wait for a "Class C-Plus" designation. If you want to evaluate how a CSP handles corrective actions, include that in your agency-specific assessment criteria and review the POA&M details in the certification package.
Next Steps
Watch for the FedRAMP Consolidated Rules for 2026 publication by June 2026. It will include complete labeling specifications, transition guidance, and marketplace filter details.
In the meantime, update your internal documentation to use "FedRAMP Certification" and the class system. The requirements haven't changed, but your procurement language needs to align with the new statutory framework before CR26 takes effect.
