Cloud

Navigating FedRAMP Rev 5 BIRs in 2026: A Practical Guide for CSPs

Jorden Foster Headshot

Jorden Foster

Senior Director, Operations Management

January 27, 2026
Healthcare Compliance Coalfire 572548896

With corrective actions that go as far as banning a Cloud Service Providers (CSPs) ability to obtain FedRAMP® authorizations, staying on top of the Rev5 Balance Improvement Releases (BIR) should be a top priority.

FedRAMP 20x requirements are making their way into Rev5 cloud services through the BIR model that was rolled about by FedRAMP in late 2025. There are two mandatory releases that need to be addressed by CSPs to avoid corrective actions.  All the requirements and recommendations can be read directly on FedRAMP.gov – within this article you’ll find the highlights of what is important and the consequences for being out of compliance.

  1. FedRAMP Security Inbox (FSI)
  • Went into effect from January 5, 2026, for Rev5 CSPs
  • Establish an email inbox to receive emergency, important, and general communications from FedRAMP/GSA
  • Whitelist applicable FedRAMP/GSA email domains
  • Set up alerting and notifications to meet response timeframes
  • Configure auto-reply or acknowledgement capabilities
  • Notify your Senior Security Official for emergency communications

If FedRAMP needs to reach a CSP, they shouldn’t need to hop through hoops or question whether their communications are being received. FSI is designed to establish clear lines of communication and expectations from CSPs in supporting this goal.

Below are the consequences of not implementing FSI requirements:

DateConsequences
March 1, 2026Public notification that the provider is not meeting the expectations of this process
May 1, 2026Complete removal from the FedRAMP Marketplace
July 1, 2026Complete removal from the FedRAMP Marketplace and a ban on FedRAMP authorization for three months.
  1. Recommended Secure Configuration (RSC)
  • Going into effect from March 1, 2026, for Rev5 CSPs
  • Designed to bolster your existing Customer Responsibility Matrix (CRM)
  • Documentation should cover (bold items must be addressed):
    • Maintenance of top-level admin accounts
    • Admin security features specific to the top-level accounts
    • What can be done by privileged accounts
    • Enabling recommended secure config settings by default
    • Comparison, export, and API capabilities around security configs
  • Make this documentation publicly available in both machine-readable and human-readable formats

Think about all that knowledge that customer success managers are sharing that isn’t represented in the CRM. RSC wants to get these good-to-know areas documented to help customers better secure their cloud portfolio.

Below are the consequences of not implementing RSC requirements:

DateConsequences
March 1, 2026Public notification that the provider does not meet this requirement
May 1, 2026Revocation of FedRAMP authorization and downgrade to FedRAMP Ready
July 1, 2026Complete removal from the FedRAMP Marketplace and a ban on FedRAMP authorization for three months

FedRAMP asks CSPs for an email as part of establishing listings on FedRAMP Marketplace. It makes a lot of sense to have this be the inbox that supports FSI requirements. Set up the right whitelisting and routing to make sure you receive these important communications from FedRAMP, while limiting the potential for spam or cold sellers to bog down these inboxes. Have an autoreply in place and setup internal response SLAs to let FedRAMP know you hear them loud and clear.

There are probably support docs that already exist for many CSPs. Take the time to review this documentation and identify what elements cover RSC requirements. If they don’t exist, go out and build them. Make sure these documents come in both machine-readable and human-readable formats and hit on the needed areas to drive security. Have coverage for those top-level admin accounts and make it clear on how secure design is achieved.