From Paperwork to Automation: The Future of FedRAMP Continuous Monitoring

Cloud Service Providers (CSPs) operating in the federal marketplace are facing a changing FedRAMP landscape. For the past year, FedRAMP has been issuing a series of new proposed rules and actively sought comments in an RFC cycle. Comment’s closed on April 22nd for one of FedRAMP’s latest Request for Comments, RFC-0026, is centered on NIST 800-53 CA-7 – the Continuous Monitoring control that requires maintenance of ongoing awareness of information security, threats, and vulnerabilities. This RFC outlines a modern way to communicate your system’s actual security posture and maintain your FedRAMP Certification under the Consolidated Rules of 2026. Essentially these changes to Continuous Monitoring will require CSPs to leverage cloud native tooling to automate the legacy, time consuming monthly paperwork drills.

In this post, we want to dive into what RFC-0026 means for you and your FedRAMP program.

The core of RFC-0026

RFC-0026 is focused on automating Continuous Monitoring, a process that is currently a paperwork exercise that is frustrating and time intensive. RFC-0026 specifies two compliance obligations that pave the way for a more automated workflow. The new vision is designed to result in better fidelity, with timely, actionable risk awareness.

1. Automated Vulnerability Reporting (RV5-CA07-VLN)

Providers have two paths to satisfy RV5-CA07-VLN. The first is the Vulnerability Detection and Response Balance Improvement Release, which requires persistent, broad vulnerability discovery across all available data sources. The second is the legacy monthly scan and POA&M approach. Under the new path, …” providers are not just performing the monthly drill but are required to persistently and promptly discover and identify vulnerabilities using all the data available, not just scan data. This provides the flexibility to include sources such as assessment results, scanning, threat intelligence, vulnerability disclosure mechanisms, bug bounties, supply chain monitoring, and other relevant capabilities. Collating all these datapoints in the legacy spreadsheets is unrealistic, and meeting the intent requires an automated solution. That’s where an automation-forward Continuous Controls Monitoring platform is a force multiplier.

2. Collaborative Continuous Monitoring (RV5-CA07-CCM)

RFC-0026 establishes RV5-CA07-CCM as a mandatory requirement. CSPs must choose between implementing the Collaborative Continuous Monitoring Balance Improvement Release (currently available in beta) or continuing the traditional collaborative ConMon approach. Under the new path providers must provide a quarterly Ongoing Authorization Report as well as minimizing legacy administrative burden by encouraging the use of automated monitoring and review of authorization data. FedRAMP recommends that participants in this beta are also following the Vulnerability Detection and Response and Significant Change Notification processes.

A Strict Timeline with Real Penalties

The grace period until December 31, 2026, offers CSPs a brief window to adapt. After that point, FedRAMP will apply corrective actions over a 12-month enforcement period that resets after each failure, meaning a provider must go 12 consecutive months without a violation to clear the record. Five failures within that period result in revocation. Third-Party Assessment Organizations (3PAOs) are instructed to document noncompliance as a high impact finding.

Automation with a Modern CCM Enabler

The new rules are driving a much higher volume of data to keep authorizing officials and other stakeholders updated on control statuses. This is why a Continuous Controls Monitoring (CCM) platform is no longer a luxury. RegScale is the pioneer in the Continuous Controls Monitoring product space; our platform is intentionally designed to automate ConMon activities into a living, automated function of your GRC program.

In a modern CCM program, security findings are automatically ingested, sorted, and organized by age. They flow directly into auto-generated POA&Ms that conform to the FedRAMP SLA windows. Every artifact is instantly exportable in OSCAL-native and Excel formats. Real-time dashboards provide agencies, Authorizing Officials (AOs), Security Control Assessors (SCAs) and 3PAOs, with persistent visibility, while proactive alerts notify your internal teams when a control slips out of compliance. This allows teams to remediate or mitigate in a risk-aware battle rhythm that doesn’t wait for the next monthly report.

RegScale enables you to do just that.

• RegScale’s robust integrations allow you to leverage data from many sources to create actionable Continuous Monitoring reports.
• RegScale’s issue management system provides a central simplified workflow to systematically track, evaluate, monitor, and manage detected vulnerabilities.

The Path Forward

The transition from a periodic compliance mindset to an ongoing, automated, data-driven security posture is no longer optional. When the grace period expires at the end of 2026, manual tracking will transform from an administrative headache into a direct threat to your federal authority to operate.

Using RegScale enables you to automate the ingestion of technical evidence and turning static documentation into live artifacts, allowing you to shift compliance from an exhausting monthly scramble into a predictable, automated way to perform Continuous Controls Monitoring.

RegScale isn’t just adapting a legacy GRC platform to these new standards. It was built from the ground up to provide persistent, automated Continuous Controls Monitoring. We don’t just meet you where you are, we’re already where you will need to be.