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Category: Authorization & Accreditation

Security Assessment Plan

Also known as:
Simply put

A Security Assessment Plan (SAP) is a document that describes which security controls will be evaluated and how the assessment will be conducted before a system is authorized to operate. It lays out the procedures, methods, and scope that assessors follow so that testing is consistent and thorough. In FedRAMP, this plan is generally prepared by an independent Third-Party Assessment Organization (3PAO).

Formal definition

A Security Assessment Plan (SAP) is a formal document that identifies the security controls and enhancements to be assessed and specifies the assessment procedures, methodologies, and scope used to evaluate a system's security posture. In the FedRAMP context, the SAP is generally developed by a Third-Party Assessment Organization (3PAO) and is used for both initial authorization assessments and, under a separate annual template, ongoing annual assessments of a Cloud Service Provider's (CSP's) system. The SAP is the planning artifact that precedes execution of testing; its results are documented separately in the corresponding Security Assessment Report (SAR). Note that the SAP itself is an assessment-planning document and does not by itself constitute an authorization decision, and template requirements and applicable revisions change over time, so readers should verify the current authoritative FedRAMP template and guidance. This entry does not address DoD RMF, CMMC, or non-FedRAMP agency-specific SAP requirements, which may differ.

Why it matters

The Security Assessment Plan is the document that gives an authorization assessment its structure and defensibility. Without a documented plan specifying which controls will be evaluated and how, an assessment risks being inconsistent, incomplete, or difficult to reproduce. In the FedRAMP context, the SAP is generally developed by an independent Third-Party Assessment Organization (3PAO), and this independence is a central reason the artifact carries weight: it establishes up front what the assessor intends to test and by what methods, so that an Authorizing Official can later trust the assessment results captured in the corresponding Security Assessment Report (SAR).

Who it's relevant to

Third-Party Assessment Organizations (3PAOs)
In FedRAMP, the 3PAO generally develops the SAP, defining the controls to be assessed and the procedures and methodologies to be used. Assessors rely on the SAP to conduct testing consistently and to align their work with the correct template for either an initial authorization or an annual assessment.
Cloud Service Providers (CSPs)
A CSP seeking or maintaining a FedRAMP authorization is the subject of the assessment the SAP describes. Understanding the SAP's scope helps a CSP anticipate what will be evaluated, distinguish the initial authorization assessment from the ongoing annual assessment, and recognize that the plan precedes rather than replaces the authorization decision.
Authorizing Officials and Reviewers
Those relying on assessment results depend on the SAP to understand the scope and rigor of what was tested. Because the SAP is a planning document and not an authorization decision, reviewers should read it alongside the resulting SAR and should not treat a completed plan as evidence that a system is secure or approved to operate.
Compliance and Assessment Coordinators
Staff managing FedRAMP assessment activities should ensure the correct and current template is used, verifying against the authoritative FedRAMP source, since template requirements and applicable revisions change over time. They should also confirm that requirements for DoD RMF, CMMC, or other agency-specific programs, which this entry does not address, are handled separately where applicable.

Inside SAP

Assessment Scope and Boundary
Defines the information system, its authorization boundary, and the specific security controls or control enhancements to be assessed. The scope generally reflects the system's categorization and the applicable control baseline, though agency tailoring may adjust which controls are in scope. Practitioners should confirm scope against the current System Security Plan (SSP) and applicable governing publication.
Assessment Objectives and Procedures
Specifies the determination statements and assessment procedures used to evaluate whether controls are implemented correctly, operating as intended, and producing the desired outcome. In most implementations these procedures draw on assessment methodology such as that described in NIST SP 800-53A, though the exact revision and any agency-specific interpretation should be verified against current authoritative text.
Assessment Methods
Identifies the methods to be applied, generally including examine, interview, and test, along with the assessment objects (specifications, mechanisms, activities, and individuals) to which each method is applied. The depth and coverage of these methods may vary based on impact level and tailoring decisions.
Roles and Responsibilities
Documents the parties involved in the assessment, which may include the assessor or assessment team, the system owner, the Information System Security Manager (ISSM), and other stakeholders. The plan clarifies who conducts the assessment versus who is responsible for the system, keeping the assessment function distinct from the authorization decision made by the Authorizing Official (AO).
Assessment Schedule and Logistics
Outlines the planned timeframe, sequencing, and resources for the assessment activities. Because authorization is time-bound and subject to continuous monitoring, the schedule should account for how assessment results feed into ongoing activities rather than a single point-in-time event.
Assessment Environment and Constraints
Notes the environment in which the assessment is performed and any known constraints, assumptions, or limitations affecting coverage. This section helps distinguish what the assessment did and did not evaluate, which is important when results are later reviewed for an authorization decision.

Common questions

Answers to the questions practitioners most commonly ask about SAP.

Does completing a Security Assessment Plan mean my system is authorized to operate?
No. The Security Assessment Plan (SAP) governs the assessment activity, not the authorization decision. The SAP describes the scope, procedures, and methods an assessor will use to evaluate security controls; it feeds into assessment results that inform the authorizing official's separate decision. Assessment and authorization are distinct steps: the SAP and the resulting Security Assessment Report (SAR) support an Authority to Operate (ATO) determination, but they do not themselves constitute one. Confirm the specific relationship between assessment artifacts and authorization decisions against your governing process, whether under the RMF for DoD systems or FISMA for civilian agency systems.
If my SAP shows the controls passed assessment, does that mean the system is secure?
Not necessarily. A favorable assessment against a SAP indicates that the assessed controls were found to be implemented as documented at a point in time, using the sampling and procedures the plan defined. Compliance demonstrated through assessment is not equivalent to security. An assessment reflects a defined scope and moment, and residual risk, undiscovered weaknesses, or gaps outside the assessment boundary may remain. Continuous monitoring and periodic reassessment are generally expected to address the fact that a system's security posture changes over time.
Who is responsible for developing the Security Assessment Plan?
In most implementations the SAP is developed by the assessor or assessment team, often in coordination with the system owner and the security officer responsible for the system. Roles and titles vary by environment, for example, the independent assessor or assessment organization role differs between DoD RMF processes and civilian agency FISMA processes. Verify the specific role assignments, independence requirements, and approval authorities that apply to your program against its governing guidance, because agency and program tailoring can differ.
What information does a Security Assessment Plan typically contain?
A SAP generally identifies the system or boundary being assessed, the security controls selected for assessment, the assessment procedures and methods to be used, the assessment schedule, and the roles of those conducting the assessment. It establishes the scope so that stakeholders agree in advance on what will and will not be evaluated. The precise required contents and format depend on the applicable framework and revision, so confirm the expected structure against your current authoritative source rather than assuming a fixed template.
How does the SAP relate to the System Security Plan (SSP) and the Security Assessment Report (SAR)?
These artifacts generally serve sequential and distinct purposes. The System Security Plan (SSP) documents how the system's security controls are implemented; the SAP defines how those implemented controls will be assessed; and the SAR captures the results of executing that assessment. In most implementations the SAP draws on the SSP to determine what must be assessed and produces findings that populate the SAR. Because these documents are interdependent, keeping the SAP aligned with the current SSP scope is generally important to avoid assessing an outdated boundary.
How often should a Security Assessment Plan be updated or reused?
A SAP is typically prepared for a specific assessment event and reflects the system scope, control selection, and procedures relevant at that time. Because system boundaries, control baselines, and applicable guidance can change across revisions, a SAP should generally be reviewed and updated when the system changes materially or when a new assessment is initiated, rather than reused unchanged. Confirm the frequency and triggers for reassessment against your program's continuous monitoring strategy and its governing authority, since specific requirements vary by environment and tailoring.

Common misconceptions

A completed Security Assessment Plan or its resulting assessment grants authorization to operate.
An assessment is distinct from authorization. The SAP guides the evaluation of controls, and the assessment produces findings; the decision to accept risk and grant an Authority to Operate (ATO) is made separately by the Authorizing Official. Assessment does not equal authorization, and any ATO that follows is generally time-bound and subject to continuous monitoring.
Passing the assessment described in the SAP means the system is secure.
Compliance demonstrated through an assessment is not the same as security. The SAP evaluates whether selected controls are implemented and operating as intended within a defined scope; it does not guarantee the absence of vulnerabilities or address risks outside the assessment boundary and constraints.
One Security Assessment Plan or its methodology applies uniformly across all federal, defense, and national security systems.
Scope and applicable requirements differ by system type and governing authority. Requirements for CUI, DoD systems under the RMF, civilian agency systems under FISMA, and classified systems may diverge, and state, local, tribal, and territorial obligations may differ. Practitioners should confirm which authority and baseline apply.

Best practices

Align the SAP scope with the current System Security Plan and the applicable control baseline, confirming which controls are in scope after any agency tailoring.
Map each assessment objective to explicit assessment methods (examine, interview, test) and assessment objects so coverage is traceable and defensible.
Keep the assessment function separate from the authorization decision, clearly documenting roles so the assessor's work remains distinct from the Authorizing Official's risk acceptance.
Document assessment constraints, assumptions, and environment limitations so reviewers understand what was and was not evaluated.
Plan for how assessment results will feed continuous monitoring rather than treating the assessment as a one-time, point-in-time event.
Verify the applicable revision of the governing assessment methodology and any agency-specific interpretations against current authoritative sources before finalizing the plan.