FedRAMP Moderate Authorization: Why It Matters for Government Security

FedRAMP is the federal government’s unified program for assessing, authorizing, and continuously monitoring cloud security.

Born out of frustration with duplicative, inconsistent security reviews across agencies, the Federal Risk and Authorization Management Program (FedRAMP) was launched in 2011 to standardize how cloud systems are evaluated.

Its purpose is clear: reduce costs, accelerate cloud adoption, and strengthen national cybersecurity posture using a repeatable framework grounded in National Institute of Standards and Technology (NIST) standards.

FedRAMP requires all participating cloud service providers to undergo independent testing by Third-Party Assessment Organizations (3PAOs). These assessments validate compliance with the Federal Information Security Management Act (FISMA) before federal agencies can adopt the service.

The result is a single, reusable authorization that multiple agencies can trust, cutting years of redundant work into a streamlined process.

FedRAMP defines three security impact levels (Low, Moderate, and High) based on the potential consequences of a breach, This tiered structure allows agencies to match security rigor to mission sensitivity, avoiding over- or under-securing systems.

These levels correspond to the confidentiality, integrity, and availability risks identified in FIPS 199, the federal standard for security categorization:

• Low (125 Controls): Applies to public-facing, non-sensitive systems. A breach here would have a limited adverse effect.
• Moderate (325 Controls): Covers most federal systems processing Controlled Unclassified Information (CUI). A breach could cause serious adverse effects.
• High (421+ Controls): Reserved for the most sensitive systems, including national security, law enforcement, and life-critical infrastructure, where a breach could be catastrophic.

FedRAMP’s three security levels are designed to align security requirements with the potential impact of a breach. Low applies to public-facing systems with minimal consequences if breached. Moderate covers systems handling sensitive but unclassified data, where a breach could cause serious harm. High is for the most critical systems, such as those supporting national security, where a breach could have catastrophic consequences. These levels ultimately help agencies apply the appropriate security measures based on the sensitivity of the data and the risks involved.

FedRAMP Moderate is the middle tier, protecting systems where compromise could cause serious harm but not a national catastrophe.

It’s also the most widely adopted level, representing roughly 80% of all authorized cloud systems in the federal marketplace. FedRAMP Moderate is the default choice for any system managing CUI, including Personally Identifiable Information (PII), case records, procurement details, and HR information.

If a system supports federal operations but doesn’t rise to the level of national security, it almost certainly falls under Moderate.

FedRAMP High adds more controls, stricter timelines, and significantly higher costs than FedRAMP Moderate.
Here’s a breakdown of how these FedRAMP levels differ:

• Controls: Moderate enforces 325 security and privacy controls from NIST SP 800-53; High requires over 421, introducing advanced cryptographic protections, personnel vetting, and near real-time monitoring.
• Data Sensitivity: Moderate is tailored for CUI. High safeguards mission-critical data tied to defense, law enforcement, or human life.
• Investment: Achieving High Authorization can cost 30–50% more, unlocking otherwise off-limited contracts.

The key point: FedRAMP High applies to agencies and contractors managing the federal government’s most sensitive workloads, while FedRAMP Moderate covers most other systems and offers a practical balance between security and cost.

FedRAMP Moderate represents a major step up in security expectations compared to Low. While Low is designed for systems where the impact of a breach would be minimal, Moderate is intended for environments that handle controlled unclassified information (CUI) or data where loss of confidentiality, integrity, or availability would be serious.
That means more controls, tighter oversight, and more rigorous proof that your security program actually works in practice, not just on paper:

• Controls: Moderate requires 325 controls — more than double the 125 in Low — covering access control, incident response, configuration management, and more.
• Authentication: Low may allow single-factor logins; Moderate mandates multi-factor authentication (MFA) for privileged and remote access to reduce account takeover risk.
• Monitoring: Low typically relies on annual assessments; Moderate requires ongoing monitoring with at least monthly vulnerability scanning and regular reporting.
• Documentation: Moderate demands detailed system security plans, incident response playbooks, and contingency plans, ensuring agencies can restore operations quickly after a disruption.

Moving from Low to Moderate means proving that systems with sensitive citizen and mission data can withstand real-world attacks, not just that the paperwork is complete.

FedRAMP Moderate enforces 325 controls across 17 domains of security.

Some of the most critical areas include:

• Access Control: Enforces MFA, least privilege, and safeguards for privileged accounts.
• Audit and Accountability: Requires comprehensive logging, long retention windows, and active analysis of security events.
• Configuration Management: Establishes secure baselines, strict change controls, and continuous monitoring for drift.
• Incident Response: Mandates formal playbooks, regular testing, and agency-aligned response processes.
• Continuous Monitoring: Demands monthly vulnerability scanning and ongoing reporting to detect and remediate weaknesses.

FedRAMP Moderate assures cloud services meet rigorous security standards, providing access to federal contracts while strengthening your organization’s security posture. It aligns with major compliance frameworks, offering both operational benefits and a clear path to federal market access.

Here are the key benefits of this distinction:

• Stronger overall security posture across the enterprise.
• A standards-based, layered defense that aligns with ISO 27001, SOC 2, and CMMC.
• Access to the federal government’s largest cloud market segment, where most contracts require Moderate.
• Better operational discipline, with formalized documentation and processes that reduce chaos in a crisis.

Compared to FedRAMP High, which applies to cloud systems with the highest risk to government operations and individuals, Moderate allows for slightly less stringent controls.

Any federal agency or contractor handling controlled unclassified information (CUI) must use a cloud service with FedRAMP Moderate authorization. This covers platforms such as HR systems processing PII, financial‑planning tools, case‑management applications, and other operational apps that underpin daily government work. For contractors, obtaining Moderate authorization is often a prerequisite for Department of Defense contracts and a stepping stone toward CMMC compliance.

If your service touches sensitive-but-unclassified data, Moderate isn’t optional — it’s mandatory.

When your systems handle data whose compromise could result in severe or catastrophic harm to government operations, public safety, infrastructure, or national security, you need FedRAMP High. This level demands the strictest controls, including more rigorous authentication, encryption, continuous monitoring, and incident‑response requirements.

One way to simplify procurement and reduce compliance risk is to adopt a service from a provider already FedRAMP High authorized. 1Kosmos, for example, has achieved FedRAMP High authorization for its identity‑verification and authentication platform.

The FedRAMP journey takes 12–18 months and follows four major phases.

1. Preparation and Planning: Classify system impact, perform a gap analysis, secure an agency sponsor, select a 3PAO, implement required controls, and draft system security plans.
2. Security Assessment: 3PAOs conduct testing, penetration assessments, and documentation validation.
3. Authorization Review: The sponsoring agency and FedRAMP Program Management Office (PMO) review results, require remediation, and issue an Authority to Operate (ATO).
4. Continuous Monitoring: Ongoing scanning, annual reassessments, and plan-of-action management ensure systems don’t drift from compliance.

Every step demands resources and discipline, but the payoff is lasting credibility across federal agencies.

All agencies handling CUI must choose Moderate-authorized providers, and many others follow suit.

Beyond federal use, state and local governments and critical infrastructure operators increasingly adopt FedRAMP standards as a benchmark for secure cloud adoption. Choosing Moderate ensures that best practices are met even outside of federal mandates.

FedRAMP High-authorized cloud services are essential for handling national security, high-impact, or life-critical workloads, but they are only necessary if your data sensitivity demands it. For most civilian and contractor systems, FedRAMP Moderate provides the best balance of cost and security. However, forward-thinking agencies may opt for FedRAMP High as a form of “future-proofing,” anticipating that their workloads could evolve to require stricter security measures over time.

1Kosmos is the only Kantara-certified, full-service credential service provider authorized at FedRAMP High.

That distinction matters because it covers all lower FedRAMP levels by default, while enabling access to the most restricted government contracts. With 1Kosmos, agencies gain:

• Security: 421+ controls, advanced cryptography, and automated flaw remediation.
• Identity Solutions: Verified biometric MFA, passwordless authentication, and user-controlled digital identity wallets.
• Compliance: Full alignment with NIST 800-63-3, FIDO2, ISO 27001, SOC 2, and more.
• Strategic Value: A single provider that spans Low, Moderate, and High use cases.

For agencies unsure whether to aim for Moderate or High, 1Kosmos eliminates the dilemma.

Government agencies are under pressure to modernize digital services while fighting a surge in identity fraud. 1Kosmos provides a FedRAMP High Authorized platform that secures both missions at once.

Traditional identity verification often fails to stop synthetic or stolen identities, leading to fraud that drains public resources and erodes trust. Worse, these outdated systems frustrate legitimate citizens who must jump through unnecessary hoops.

1Kosmos changes the equation. With a user-friendly self-service enrollment process, agencies can:

• Detect and block fraudulent identities with 99%+ accuracy across 150 countries.
• Issue strong, privacy-preserving digital identity wallets.
• Replace vulnerable passwords with phishing-resistant biometric MFA.
• Give citizens full control of their information, secured on a distributed ledger.

The result is secure, seamless, citizen-first digital services that both protect resources and enhance public trust.

Ready to protect public resources, eliminate fraud, and streamline service delivery? Discover how 1Kosmos Government Solutions can power your secure digital transformation today.