FedRAMP Moderate Equivalency

FedRAMP Moderate Equivalency is a compliance pathway recognized by the Department of Defense that allows cloud service providers to demonstrate they meet the security control requirements of FedRAMP Moderate without holding a formal FedRAMP authorization package. Rather than completing the full FedRAMP Joint Authorization Board or agency ATO process, a provider documents and attests that its security posture maps to FedRAMP Moderate controls, and the relevant DoD component reviews and accepts that determination.

What is FedRAMP Moderate Equivalency?

The legal and policy basis for this pathway comes from DoD Instruction 8510.01, which governs the DoD Risk Management Framework, and the DoD Cloud Computing Security Requirements Guide (CC SRG) published by DISA. The CC SRG establishes impact levels for DoD cloud use, and Impact Level 2 (IL2), covering DoD unclassified data that is not Controlled Unclassified Information, corresponds to the FedRAMP Moderate control baseline. Under IL2, DoD components may accept cloud services that demonstrate equivalency to FedRAMP Moderate controls through documented self-attestation rather than requiring a full FedRAMP ATO.

The equivalency determination process requires the cloud service provider to produce a System Security Plan or equivalent documentation showing how its controls map to the FedRAMP Moderate baseline. The DoD component's authorizing official reviews the documentation and issues a local authorization or provisional acceptance. This approach is particularly common for commercial SaaS tools used by DoD program offices that serve narrow operational needs and where the full FedRAMP process would impose disproportionate cost and timeline relative to the risk involved.

It is important to note that FedRAMP Moderate Equivalency is not a shortcut to serving civilian agencies. Federal civilian agencies governed by OMB policy generally require a formal FedRAMP ATO from the Marketplace. The equivalency pathway is a DoD-specific accommodation.

Why it matters for contractors

Defense contractors who use cloud-based collaboration tools, project management platforms, engineering software, or other commercial SaaS products in the performance of DoD contracts must ensure those platforms comply with the cloud security requirements in their contracts. When a contract requires cloud services to meet DoD CC SRG IL2, the platform must either hold a FedRAMP Moderate ATO or have a documented equivalency determination accepted by the DoD component. Using a non-compliant platform can constitute a material breach of contract and may trigger findings during compliance assessments or audits.

For cloud service providers, the equivalency pathway lowers the barrier to initial entry into the DoD market. A provider can pursue equivalency while simultaneously working toward full FedRAMP authorization, generating DoD revenue in the interim. Understanding which DoD customers will accept equivalency versus require a formal ATO is a critical business development question.

Example

A small defense contractor uses a commercial project management SaaS tool to coordinate engineering work on a Navy program. The contract includes a clause requiring all cloud services handling DoD information to meet DoD CC SRG IL2 requirements. The SaaS provider has not yet obtained a FedRAMP Moderate ATO but has produced a detailed security control mapping document demonstrating equivalency. The contractor submits the provider's equivalency package to the Navy contracting officer's representative, who routes it to the program's authorizing official for review. The authorizing official accepts the equivalency determination, and the contractor is cleared to continue using the tool under the program's approved cloud inventory.