The Conventional Wisdom
Cloud service providers often think they should wait for the General Services Administration (GSA) to complete the FedRAMP 20x rollout before diving into the new requirements. They believe sticking with Rev 5 authorizations is safer until the new processes are clear. This seems logical since GSA is in phase three of five, with new Class A, B, and C certifications being formalized. Phase four will pilot Class D certifications, and phase five will eventually phase out new Rev 5 offerings. The timeline suggests patience is wise.
It isn't.
Why You Shouldn't Wait
Waiting for FedRAMP 20x to "settle" misunderstands how authorization programs evolve and how your competitors are already adapting. Providers who delay 20x preparation aren't avoiding confusion; they're setting themselves up for it when agencies start requiring the new certifications.
GSA has already made significant progress in phases one and two, testing new rules, adjusting unclear requirements, and refining processes. FedRAMP Security Director Nicole Thompson noted that while there was initial frustration over information overload, "over the last year and a half, people have adjusted."
This adjustment period benefited early participants. If you're waiting, you're choosing to compress your learning curve into whatever time remains before your next authorization cycle or before an agency sponsor demands a 20x certification.
The market implications are clear. A cloud service provider at a recent federal cloud forum stated, "Think about all the breaches that happen... most of the time, when it's those cloud systems, it's not the FedRAMP instance of that system that's getting breached." FedRAMP-authorized environments consistently show stronger security than their commercial counterparts. As 20x becomes the standard, agencies will prefer providers who've already transitioned.
The Evidence
GSA's communication strategy shows where they expect providers to be. They've set up GitHub discussion boards, launched a YouTube channel for updates, and expanded their help desk. These resources are for now, not a future state.
Thompson highlighted that many people rely on outdated advice instead of using current resources. The problem isn't a lack of 20x guidance; it's that providers aren't looking in the right places or aren't looking at all.
Agencies are already asking questions that assume 20x knowledge. The Centers for Medicare and Medicaid Services is working with FedRAMP to speed up authorizations for cloud services under the new regime. Your agency sponsors will have similar expectations. When they ask about Class B certification timelines or automation requirements, "we're waiting for things to stabilize" won't suffice.
The push for automation in 20x isn't optional. The reform aims to speed authorizations by reducing red tape and encouraging automation. If your processes still rely on manual documentation, you're not just behind on 20x; you're using a compliance model the program aims to retire.
What to Do Instead
Start with the primary sources GSA provides. Review the FedRAMP GitHub repositories for updated requirements and guidance. Subscribe to the YouTube channel for program updates. Avoid relying on outdated Rev 5 guidance or old blog posts.
Map your current authorization approach to the new certification classes. Determine which class your offerings require and what the differences mean for your System Security Plan, continuous monitoring strategy, and evidence requirements. This requires a thorough comparison of your controls against updated baselines.
Evaluate your automation capabilities honestly. Identify where you're still generating compliance artifacts manually and which procedures could be automated. The 20x focus on automation means your authorization timeline will depend on how much evidence you can produce programmatically.
Engage with the FedRAMP help desk before you're under pressure. Ask specific questions about how 20x requirements apply to your architecture. Use the help desk when you have time to implement the answers, not when you're trying to close findings.
If you're currently authorized under Rev 5, don't assume you'll simply renew when your cycle ends. Phase five will end new certifications for legacy Rev 5 offerings. Plan your transition to a 20x certification class before your authorization expires.
When Waiting Makes Sense
There are times when patience is wise. If you're a small provider with limited resources and not pursuing a new authorization soon, focusing on maintaining your current authorization might be better. Keep your Rev 5 authorization in good standing and monitor critical 20x updates without overhauling your compliance program prematurely.
If your agency sponsors have confirmed they're comfortable with Rev 5 for now, and you have documentation of this, you have some breathing room. Confirm this position quarterly, as agency preferences can change quickly.
For providers waiting on specific certification classes like Class D, some patience is warranted. But "waiting for Class D" is different from "waiting for the whole program to stabilize." You should still understand Classes A, B, and C thoroughly.
The idea of waiting for stability isn't entirely wrong. It's just applied at the wrong level. Wait for specific technical guidance on edge cases if needed. Don't wait to understand the fundamental shift FedRAMP 20x represents. Your competitors aren't waiting. Your agency sponsors aren't waiting. And GSA has moved past the "managing frustration" phase into the "people have adjusted" phase.
The question isn't whether you'll need to understand 20x. It's whether you'll do it on your timeline or someone else's.
