FedRAMP Rev5 Class C Certification

How much does FedRAMP Rev5 Class C cost?

$150,000 all-in with Sequencer Assurance providing all GRC technology and tooling, or a custom quote when the client provides GRC tooling.

• Client tooling: custom quote. The client provides the GRC technology and tooling, including a FedRAMP-compatible trust center. Priced per client because tooling varies widely. (CDS-CSO-UTC)
  • The full fixed-scope Rev5 Class C engagement
• All-in: $150,000. Sequencer Assurance provides all GRC technology and tooling, including the trust center. (CDS-CSO-UTC, CDS-TRC-PAC, CDS-TRC-ACL, CDS-TRC-AAI)
  • The full fixed-scope Rev5 Class C engagement
  • All GRC technology and tooling, provided by Sequencer Assurance

How is it billed?

• 50% at Kickoff
• 50% at Independent assessment performed

Optional add-ons

• GRC tools from the client's maturity roadmap (quoted separately). Sequencer Assurance is a vendor-neutral value-added reseller (VAR) of GRC tools. Products recommended on the client's maturity roadmap may be added and are priced separately from the fixed fee. Requires client approval before purchase.

What costs are outside the fee?

• Independent assessment by a FedRAMP Recognized assessor (required initially, then 35 named controls every year and all controls every 3 years)
• Licensing for the client's own GRC tooling and trust center (client tooling tier)

How long does FedRAMP Rev5 Class C take?

About 4 to 8 weeks of Sequencer Assurance and client work, plus the independent assessment. Marketplace listing and the operational build-out run alongside control implementation and documentation.

Total: 4–8 weeks (estimate).

Client time: 20–60 hours in total. Spread across the engagement.

Phases

1. Scope and gap assessment (1–2 weeks; owner: Sequencer Assurance). Confirm the Rev5 Class C certification profile and path, define the Minimum Assessment Scope with information flows and third-party resources, and measure the gap against every Class C rule and control. Deliverables: Class C gap report.
2. Marketplace listing (1 day; owner: Shared). Publish the required public information about the cloud service offering as web pages and JSON, document progress milestones, and request the FedRAMP Marketplace listing. Deliverables: Public cloud service offering information.
3. Control implementation and documentation (1–2 weeks; owner: Shared). Close gaps in the 322 required controls, assign every organization-defined parameter, and document each control following FedRAMP Rev5 Controls Guidance. Deliverables: Control implementation documentation.
4. FedRAMP operational build-out (1–2 weeks; owner: Shared). Stand up the security inbox, incident reporting, vulnerability detection and monthly reporting, significant change notifications, Ongoing Certification Reports and Quarterly Reviews, availability reporting, the trust center, the Secure Configuration Guide, and cryptographic module documentation. Deliverables: FedRAMP operating runbooks, Ongoing Certification Report and Quarterly Review kit, Secure Configuration Guide.
5. Certification package authoring (1–2 weeks; owner: Sequencer Assurance). Write the Certification Package Overview and Security Decision Record, including control summaries, parameter assignments, and relevant policies, in human-readable and JSON form validated against FedRAMP's schemas. Deliverables: Certification package, Sample incident, change, and vulnerability reports.
6. Independent assessment (Scheduled by the assessor; not included in the estimate; owner: Assessor). A FedRAMP Recognized assessor verifies and validates the cloud service offering. Sequencer Assurance provides independent assessment support: evidence preparation, technical walkthroughs, and help responding to findings. Deliverables: Assessment support.
7. Final validation and client submission (1–2 weeks; owner: Client). Add the assessment summary to the package, re-verify it against the live cloud service offering, then the client submits the FedRAMP Certification Application within 3 months of the assessment. On the agency path, the sponsoring agency also sends its signed ATO letter to FedRAMP. Deliverables: Submission kit.
8. FedRAMP review (Set by FedRAMP; not published in the rules dataset; owner: FedRAMP). FedRAMP reviews the package and issues a certification report. Sequencer Assurance answers questions and makes corrections during review.

Estimates cover Sequencer Assurance and client work only. Time for the independent assessment, which the assessor schedules, and for FedRAMP-owned activities, such as Marketplace listing approval and certification review, is not included, and Sequencer Assurance cannot control delays caused by the assessor, FedRAMP, or GSA.

What deadlines do the FedRAMP rules set?

• Assessment freshness (up to 3 months): The independent assessment must have been completed by a FedRAMP Recognized assessor within the previous 3 months at application. (FRC-APP-FIA)
• Package freshness (up to 7 days): The submitted package must show the cloud service offering's status as verified and validated within the previous 7 days. (FRC-APP-FCP)
• Marketplace assessment deadline (up to 2 years): An assessment for Class B, C, or D must be scheduled within 2 years of the initial Marketplace listing, or FedRAMP removes the listing. (MKT-IIP-DLA)
• FedRAMP Ready conversion (Fixed date: November 17, 2026, or annual assessment expiry if later): Cloud service offerings with FedRAMP Ready status must convert to a FedRAMP Certification by November 17, 2026 or the expiration of their annual assessment, whichever is later. (FRC-CSF-RDY)

Who is FedRAMP Rev5 Class C for?

• Cloud service offerings already instructed by an existing government or government-adjacent customer or prospect to pursue a FedRAMP Rev5 Class C certification
• Cloud service offerings with an agency sponsor ready to issue an Authorization to Operate
• Cloud service offerings with FedRAMP Ready status that must convert to a FedRAMP Certification
• Cloud service offerings with a Class A or Class B Certification that need Class C

Who is it not for?

• Cloud service offerings whose only government use is meeting other compliance programs such as CMMC
• Cloud service offerings pursuing a FedRAMP 20x Program Certification
• Cloud service offerings that need a Class B or Class D Certification

Who is eligible for FedRAMP Rev5 Class C?

• Required: A federal use case: direct use by agencies, or inclusion in another cloud service offering that agencies use directly. (MKT-IIP-AGU, MKT-FRP-SOF)
• Required: Not concurrently seeking a FedRAMP 20x Program Certification for the same cloud service offering. (FRC-CSO-POP)
• Required: Budget for an independent assessment by a FedRAMP Recognized assessor, initially and every year after certification. (FRC-APP-FIA, IVV-CSO-FIA)
• Required: Agency path only: the sponsoring agency completes its Authorization to Operate and sends the signed ATO letter to FedRAMP. (FRC-APS-ATO)
• Preferred: An existing FedRAMP Ready status, Class A Certification, SOC 2 Type II, or GovRAMP assessment shortens the work but is not required.

What does the client get from FedRAMP Rev5 Class C?

• A FedRAMP Marketplace listing with public human-readable and JSON information about the cloud service offering
• Implementation and documentation of all 322 NIST SP 800-53 Rev. 5 controls required for Class C, with every organization-defined parameter assigned
• Running FedRAMP processes: security inbox, incident reporting, monthly vulnerability reporting, significant change notifications, quarterly Ongoing Certification Reports, and Quarterly Reviews
• A complete, schema-valid certification package that includes the independent assessment results, ready for the client to submit
• A Security Decision Record that addresses every MUST and SHOULD Class C rule and control with an accurate implementation status, the independent assessor's summary for each, and timeframed plans for anything not yet fully implemented
• Package files FedRAMP can open from the trust center without an NDA or terms of service, so the package clears FedRAMP's pre-queue verification and enters the Review Queue sooner

What are the deliverables?

• Class C gap report (PDF, JSON): Status of every Class C rule and control against the current cloud service offering, with owners and effort, and the optional rules the client already meets and can take credit for in the Security Decision Record. (FRC-CSO-FCP, MAS-CSO-IIR, MAS-CSO-FLO, MAS-CSO-TPR)
• Public cloud service offering information (HTML, JSON): Human-readable page and JSON feed with FedRAMP ID, service list, contacts, trust center link, and next report and review dates. (CDS-CSO-PUB, CDS-CSO-SVC, CCM-OCR-NRD, CCM-QTR-NRD)
• Control implementation documentation (JSON, Markdown): Implementation summaries for the 322 required controls and the organization-defined parameter assignments. (FRC-CSF-BSL, FRC-CSF-ACP, FRC-CSF-FFG, SDR-CSF-CTF)
• FedRAMP operating runbooks (Markdown, PDF): Procedures for the security inbox, incident reports, vulnerability detection, evaluation and monthly reporting, and significant change notifications. (AFC-CSO-INB, IEC-CSO-IIR, IEC-CSO-OIR, IEC-CSO-FIR, VDR-CSO-RES, VER-TFR-MHR, SCN-CSO-EVA)
• Ongoing Certification Report and Quarterly Review kit (PDF, JSON): Quarterly report template and example, feedback mechanism, and Quarterly Review agenda and registration setup. (CCM-OCR-AVL, CCM-OCR-FBM, CCM-QTR-REG)
• Secure Configuration Guide (HTML, PDF): Recommended secure settings for the cloud service offering, with instructions in the package for obtaining and using it. (SCG-CSO-RSC, SCG-CSO-AUP)
• Certification package (HTML, JSON): Certification Package Overview and Security Decision Record covering every MUST and SHOULD Class C rule and control. Each entry carries an implementation status, the independent assessor's assessment summary, and, where partially or not implemented, the reason and a plan with timeframes. Includes control summaries, relevant policies, cryptographic module documentation, and every referenced artifact and piece of evidence, all reachable from the trust center without an NDA or terms of service. (FRC-CSO-PKG, CPO-CSO-OVR, SDR-CSO-FRR, CDS-CSO-IRP, CMU-CSO-CMD, IVV-IAS-SUM)
• Sample incident, change, and vulnerability reports (HTML, JSON): Filled samples of the Initial, Ongoing, and Final Incident Reports, a Significant Change Notification, and vulnerability reporting with vulnerability details and accepted vulnerability information, plus historical vulnerability detection and response activity, in human-readable and machine-readable form. FedRAMP expects these samples in the package even before any incident, change, or report has occurred. (IEC-CSO-IIR, IEC-CSO-OIR, IEC-CSO-FIR, SCN-CSO-INF, VER-RPT-VDT, VER-RPT-AVI, VER-TFR-MRH)
• Assessment support (JSON, PDF): Evidence of implementation and effectiveness organized for the assessor, technical walkthroughs, and help responding to findings. (IVV-CSO-SEI, IVV-CSO-SEE, IVV-CSO-ICP)
• Submission kit (PDF): Final validation record, the assessor's overall summary added to the package, and a pre-filled guide for the client's FedRAMP Certification Application Form. (FRC-APP-FCP, FRC-APP-FIA, CPO-CSO-OSA, IVV-IAS-OSA, FRC-APP-AFC, FRC-APP-NTP, FRC-APS-ATO)

What is included?

• Gap assessment against all 101 required Class C rules and 322 required controls, plus the optional rules the client already meets
• Control documentation, the certification package, public JSON, and the Secure Configuration Guide in human-readable and machine-readable form, checked with FedRAMP's JSON Schema Validator
• Sample incident, significant change, vulnerability, and Ongoing Certification Reports for the package
• A trust center access check so FedRAMP can open every package file without an NDA or terms of service
• A lean package: only material that supports FedRAMP's risk-based decision, since FedRAMP reviews everything included
• Process design for inbox, incident, vulnerability, significant change, and quarterly reporting rules
• Evidence preparation and support during the independent assessment
• Support during FedRAMP review

What is not included?

• The independent assessment itself, which a separate FedRAMP Recognized assessor performs
• The sponsoring agency's Authorization to Operate process on the agency path
• Submitting the application on the client's behalf, which FedRAMP prohibits
• Engineering changes to the client's systems

What does the client need to do?

• Name a technical owner and an executive sponsor
• Agency path: coordinate the Authorization to Operate with the sponsoring agency
• Engage and pay a FedRAMP Recognized assessor
• Supply evidence of implementation and effectiveness to the assessor
• Submit the FedRAMP Certification Application Form
• After handover, keep the package current at least yearly, verify machine-based resources monthly, report vulnerability activity monthly, produce the quarterly Ongoing Certification Report and host the Quarterly Review, and include previously failed controls in the next assessment (CPO-CSF-CPM, VDR-TFR-MVF, VER-TFR-MHR, CCM-OCR-AVL, CCM-QTR-MTG, IVV-CSF-ACF). Drop Sequencer Assurance a note about custom retainers

Frequently asked questions

Which FedRAMP rules does FedRAMP Rev5 Class C cover?

Each rule, its force, and the phase where Sequencer Assurance handles it.

Related services

• FedRAMP 20x Class C Certification: Class C on the 20x path, using Key Security Indicators.
• FedRAMP Rev5 Class B Certification: Rev5 Class B, for cloud service offerings that need less assurance.
• FedRAMP 20x Class A Certification: Class A can cover agency use for up to 12 months while Class C is underway.