From Attestation to Assurance: Signals from a Changing Federal Landscape

Many organizations still approach compliance as a project with a beginning and end. That may have worked several years ago. But today, regulations are no longer static. New requirements emerge constantly, threat actors evolve daily, and organizations themselves are transforming through their use of new technologies. Taken together, these trends are forcing companies to change the way they do compliance.

A great example of the evolving landscape is FedRAMP 20x. It’s a long overdue effort to ease the compliance burden on suppliers and ensure that more innovative products and vendors are made available to government buyers. With a heavy focus on automation and continuous monitoring, there are some big efficiency wins there for the taking.

A Changing World

The world is becoming more dangerous. Threat actors are leveraging AI and the power of the cybercrime economy to innovate in unpredictable ways. Nation states are emboldened and historic incidents — from SolarWinds to MOVEit — have shown that when government agencies are hit, it’s usually via the supply chain.

At the same time, federal suppliers are expanding their own attack surface with cloud adoption, AI usage, SaaS expansion and flexible, distributed workforces. A report last year found that 58% of breaches impacting the top 100 U.S. federal contractors involved third-party attack vectors.

Against this backdrop, FedRAMP is more important than ever in helping government entities assess, authorize and monitor cloud service providers (CSPs). But it also needed to change. The authorization process was painfully slow, expensive, and centered around mountains of manual paperwork.

Towards Streamlined and Continuous Compliance

In this context, FedRAMP 20x is an ambitious and welcome development. It’s recognition that static assessments cannot keep pace with modern cloud environments, software delivery pipelines, and evolving threats. It signals that the future of compliance must be far more operational, data-driven, and continuous.

Several changes underpin this new approach. FedRAMP 20x will:

• Shift away from prescriptive administrative controls to Key Security Indicators (KSIs) that serve as measurable, data-driven security metrics to drive real-world outcomes
• Swap the Significant Change Request (SCR) for the Significant Change Notice (SCN), allowing cloud providers to innovate without having to wait for formal approvals
• Minimize redundant approvals and shrink authorization timelines by overhauling the reviews process to give agencies more autonomy

The goal is to transform compliance with the program into a continuous, automation-driven process based around compliance as code. It’s a reflection of a broader industry realization that organizations must move towards machine-readable evidence, automated validation, continuous monitoring, and real-time assurance.

Security environments simply change too quickly for quarterly or annual snapshots to provide sufficient confidence. Automation improves both security and scalability.

The Road Ahead

The organizations that will succeed in this new era of federal modernization will be those that treat compliance as engineering rather than paperwork. They’ll focus on automated evidence collection, strong cloud-native telemetry, and API-driven integrations. They’ll gain real-time visibility, drive continuous controls monitoring, and work to develop policy-as-code and infrastructure-as-code maturity.

We see three areas where innovation will drive real transformation:

• Compliance as code will support a scalable, standards-based way of conducting real-time, automated, full-lifecycle security assessments. The NIST OSCAL standard translates controls into code. That means your System Security Plan (SSP), Security Assessment Plan (SAP), Security Assessment Report (SAR), and Plans of Action and Milestones (POA&Ms) become machine-readable, so compliance gaps are instantly flagged. Meanwhile, OCSF simplifies continuous monitoring and data sharing by creating a common language for assets, vulnerabilities, configurations, and tickets.
• AI innovation will be a game changer for selecting controls, performing control attestations, identifying POA&Ms, and supporting risk assessments. RegScale’s AI Explainer offers context-based explanations of security controls in plain language. Our AI Author generates SSP packages based on existing policies, other certifications, or high-level questionnaire responses. And our AI auditor reviews SSP packages to generate the SAP/SAR.
• A Universal Mapping Framework could help map controls across all common frameworks, enabling security vendors to perform one attestation and then apply it to overlapping frameworks. That would be a great foundation for continuous monitoring automation across the industry.

Times Are Changing

Compliance can no longer be treated as a periodic process. Organizations that still rely heavily on manually gathering screenshots and spreadsheets will struggle in the years to come. The speed and scale expected under modern assurance models will simply outpace manual operations. Federal modernization means the conversation has shift from assumed trust to continuously validated trust. Can your organization prove that it can actively manage risk 24/7?

These changes haven’t been made on a whim. FedRAMP 20x is the culmination of over a year’s worth of collaborative planning between government agencies and comments from industry stakeholders, including RegScale, on requirements as they were being finalized. It’s also aligned with best practice Zero Trust principles, which hold that trust is never permanent and verification is continuous.

The good news is that the technology exists today to start your FedRAMP 20x compliance journey. RegScale has demonstrated a full compliance workflow that can be executed in just 90 minutes. But putting the right tools in place is only one piece of the puzzle. Continuous assurance also requires cross-functional collaboration. Organizations must break down the silos between security, compliance, engineering, and operations to move forward.

As we enter a new age of continuous monitoring, validation, and assurance, let’s not forget that compliance success is about people as well as technology.