FedRAMP®

Did FedRAMP Just Kill the Idea of “Sponsors”?

James Masella

James Masella

VP, Compliance Advisory, Coalfire

February 26, 2026
Advisory Blog Did Fed RAMP Just Kill the Idea of Sponsors 4

For nearly fifteen years, one word has defined the emotional experience of entering FedRAMP:  sponsor.

If you were a cloud service provider (CSP), success often hinged less on your technical readiness and more on whether you could convince a federal agency to “take you through” the FedRAMP process. Sponsors were gatekeepers, champions, risk absorbers, and—at times—bottlenecks.

With the release of FedRAMP Notice NTC‑0004, which documents the initial outcome of RFC‑0020: FedRAMP Authorization Designations, that long‑standing model may finally be coming to an end—or at least being fundamentally redefined. [fedramp.gov]

So the question is fair to ask:

Did FedRAMP just kill the idea of sponsors?

The Old World: Sponsorship as a Prerequisite

Historically, the FedRAMP process has been framed—formally or informally—around agency sponsorship. A CSP pursuing an agency authorization typically needed:

  • A federal customer willing to commit time, staff, and political capital
  • An Authorizing Official (AO) prepared to own the residual risk
  • A contract vehicle or near‑term mission need to justify the effort

In practice, this meant many CSPs were FedRAMP‑ready but stuck in limbo, unable to move forward without an agency sponsor—even if multiple agencies wanted the service but none wanted to go first.

This dynamic constrained competition, slowed cloud adoption, and overloaded security teams with process overhead unrelated to mission outcomes.

FedRAMP leadership has acknowledged for several years that the term “authorization” itself contributed to confusion, leading CSPs and agencies alike to incorrectly assume FedRAMP equaled a government‑wide ATO. [fedramp.gov]

RFC‑0020 and Notice 0004: A Structural Shift

Notice NTC‑0004, published February 25, 2026, lays out how FedRAMP plans to implement the outcomes of RFC‑0020 in the upcoming FedRAMP Consolidated Rules for 2026 (CR26)[fedramp.gov]

The most consequential change is this:

A FedRAMP authorization is now formally defined as a “FedRAMP Certification.”

Under this model:

  • FedRAMP, not an agency, issues the certification
  • All certified cloud services use a single label: FedRAMP Certified
  • Certifications are grouped into four classes (A, B, C, and D) aligned to existing baselines

FedRAMP explicitly states that these classes reflect the scope of assessment and certification, not the overall “quality” or security maturity of the service. [fedramp.gov]

Just as importantly, the notice reinforces a clean separation of responsibility:

  • FedRAMP certifies cloud services
  • Agencies authorize systems for use (ATO)

That distinction has always existed in theory. RFC‑0020 makes it unavoidable in practice.

What Happens to Sponsors?

This is where the traditional sponsorship model starts to break down.

Under the new framework, a CSP can pursue and achieve FedRAMP Certification without being pulled through the process by a specific federal agency. Certification becomes a reusable, market‑wide artifact rather than a byproduct of a single agency’s procurement decision.

Agencies still:

  • Select services
  • Integrate them into systems
  • Accept risk and issue ATOs

But they no longer have to shepherd a CSP through FedRAMP just to make acquisition possible.

In other words, the sponsor role shifts from “process enabler” to “risk decision‑maker.”

That is a profound change.

The Contracting Implications Are Bigger Than the Security Ones

One of the most underappreciated consequences of this shift is what it enables on the acquisition side.

With standardized certification classes (A–D), contracting offices can realistically begin to:

  • Specify “FedRAMP Certified (Class B)” as a solicitation requirement
  • Evaluate vendors without asking which agency sponsored them
  • Separate cloud security due diligence from mission‑specific risk acceptance

FedRAMP itself notes that the new labels are designed to reduce confusion in procurement and acquisition discussions, particularly where “authorization” language previously implied blanket approval. [fedramp.gov]

This opens the door to a future where:

  • FedRAMP certification is table stakes, like SOC 2 or ISO 27001
  • ATOs are tailored, contextual, and faster
  • Cloud adoption scales without scaling FedRAMP bottlenecks

What This Does Not Mean

Let’s be clear about what FedRAMP did not do.

  • Agencies did not lose ATO authority
  • FedRAMP did not create a government‑wide ATO
  • Risk acceptance did not move “up” to FedRAMP

The notice explicitly states that a FedRAMP Certification merely establishes adequacy for an agency to authorize use within its own system. [fedramp.gov]

Sponsors, in the sense of accountable Authorizing Officials, are still very much alive.

What’s gone is the idea that agencies must act as process sponsors just to get CSPs through the door.

So…Did FedRAMP Kill Sponsors?

Not exactly.

FedRAMP killed the gatekeeping sponsor model—the one where progress depended on finding the “right” agency at the “right” time with the “right” appetite for paperwork.

In its place, FedRAMP is building something more scalable:

  • CSP‑driven certification
  • Agency‑driven authorization
  • Contracting‑friendly security signals

That’s not the end of sponsorship. It’s the end of sponsorship as a prerequisite for participation.

And for the federal cloud ecosystem, that might be the most important FedRAMP change yet.

 

Source:

  • FedRAMP Notice NTC‑0004, “Initial Outcome from RFC‑0020 FedRAMP Authorization Designations” (Feb 25, 2026) [fedramp.gov]
  • RFC‑0020: FedRAMP Authorization Designations [fedramp.gov]