Don’t Be Fooled: “FedRAMP Equivalency” Claims Put CMMC Compliance at Risk

Key Takeaways

1. True FedRAMP equivalency requires C3PAO assessment: Cloud service providers must undergo evaluation by a FedRAMP-recognized third-party assessor organization to legitimately claim equivalency.
2. DoD issued clarifying guidance in 2024: The January 2024 memo specifically addresses misconceptions about FedRAMP equivalency to prevent unsubstantiated security claims.
3. FedRAMP Moderate requires 325 security controls: Any equivalent solution must implement 100% of these NIST-based controls without exceptions or gaps.
4. Unverified equivalency claims create compliance risks: Contractors face potential CMMC audit failures and contract violations when accepting unsubstantiated security assertions.
5. Verification requires documented evidence: Defense contractors must request specific assessment documentation rather than relying on marketing claims for compliance.

Understanding FedRAMP Equivalency

FedRAMP equivalency has become a critical consideration for defense contractors managing Controlled Unclassified Information (CUI) in cloud environments. But what exactly does this term mean, and why is it so important for your CMMC compliance strategy?

FedRAMP equivalency refers to cloud service offerings that meet security requirements comparable to those mandated by the Federal Risk and Authorization Management Program (FedRAMP) Moderate baseline. For defense contractors subject to DFARS 7012 requirements, understanding the distinction between genuine FedRAMP equivalency and marketing claims is essential for maintaining both security and contractual compliance.

The DoD’s Official Guidance on FedRAMP Equivalency

On January 2, 2024, the Department of Defense released a crucial memorandum clarifying the requirements for FedRAMP Moderate equivalency. This guidance was specifically issued to address confusion in the marketplace and prevent cloud service providers (CSPs) from making unsubstantiated claims about their security posture.

The memo establishes that to achieve true FedRAMP equivalency, cloud service providers must:

1. Implement 100% of the current FedRAMP Moderate security controls
2. Undergo assessment by a FedRAMP-recognized certified third-party assessor organization (C3PAO)
3. Maintain comprehensive documentation of their security controls and implementation

This official DoD guidance serves as the definitive reference for contractors evaluating cloud services for CMMC compliance.

FedRAMP Equivalency vs. FedRAMP Moderate Authorization

Understanding the key differences between FedRAMP equivalency and full FedRAMP Moderate Authorization is essential for defense contractors:

While certifications like ISO 27001, HITRUST CSF, and DoD Provisional Authorizations provide valuable security frameworks, they do not automatically satisfy FedRAMP equivalency requirements without additional validation.

What Defense Contractors Need to Know About FedRAMP Equivalency

DFARS 7012 mandates that contractors only use cloud services that meet FedRAMP Moderate security requirements or equivalent. However, the increasing number of CSPs claiming “FedRAMP equivalency” without proper verification has created significant compliance risks.

When CSPs make vague claims about equivalency without undergoing legitimate 3PAO assessments, contractors face:

• Potential CMMC compliance failures during audits
• Increased vulnerability to cyber threats targeting CUI
• Risk of contract termination due to security requirement violations
• Possible False Claims Act liability for misrepresenting compliance status

The stakes are high: using a cloud service with unverified “equivalency” claims could jeopardize both your security posture and your ability to maintain DoD contracts.

How to Validate True FedRAMP Equivalency Claims

The DoD memo provides clear criteria for validating FedRAMP equivalency claims. Before trusting a CSP’s assertions, contractors should verify:

1. Complete Control Implementation: Confirm 100% compliance with all 325 FedRAMP Moderate controls, with no exceptions or gaps.
2. Qualified Assessment: Verify that assessment was conducted by an accredited 3PAO, not self-assessment or by non-recognized assessors.
3. Documentation Requirements: Request the Security Assessment Plan (SAP) and Security Assessment Report (SAR) that document the evaluation process.
4. DFARS 7012 Alignment: Ensure the CSP has implemented all required cyber incident reporting and response capabilities.
5. Continuous Monitoring: Confirm ongoing security monitoring and vulnerability management practices align with FedRAMP requirements.

Don’t simply accept marketing claims about equivalency. Request documented evidence that meets these specific requirements to ensure your CMMC compliance strategy rests on a solid foundation.

Achieving CMMC Compliance with FedRAMP Moderate Authorization

The most reliable path to ensuring cloud service compliance with DFARS 7012 and CMMC requirements is to select providers with established FedRAMP Moderate Authorization. This approach offers several advantages:

• Verified Security Posture: FedRAMP Moderate Authorization provides independently verified evidence of robust security controls.
• Simplified Compliance: Using authorized services streamlines the path to CMMC compliance for cloud-hosted CUI.
• Reduced Risk: Authorization indicates the CSP has successfully implemented controls specifically designed to protect government data.
• Accelerated Procurement: FedRAMP-authorized services support faster implementation timelines with reduced compliance overhead.

Kiteworks, with its FedRAMP Moderate Authorization since 2017, delivers a Private Data Network that enables defense contractors to securely manage CUI with:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Comprehensive security integrations (DLP, ATP, SSO, LDAP/AD, SIEM, MFA)
• Comprehensive audit logs for regulatory compliance
• Single-tenant deployment with dedicated encryption keys

By selecting a properly authorized cloud service provider, contractors can focus on their core missions while maintaining confidence in their CMMC compliance posture.

Protect your defense contracts and ensure CMMC compliance by understanding the critical requirements for FedRAMP equivalency. Schedule a custom demo to learn how Kiteworks’ FedRAMP Moderate Authorized platform can secure your controlled unclassified information while maintaining regulatory compliance.

Additional Resources

• Blog Post FedRAMP: The Short Path to Secure Content Communications
• Brief Meeting the FedRAMP Equivalency Requirement of CMMC
• Brief Kiteworks Comparison: On-premises vs. Hosted vs. FedRAMP
• Blog Post Managed File Transfer With FedRAMP Compliance
• Blog Post FedRAMP Audit Logging [Best Practices, Solutions, and Tips]