The FedRAMP® Assumption Jeopardizing CMMC Readiness

Contractors in the Defense Industrial Base (DIB) are getting pulled in two directions at once.

On one side, the US government is ratcheting up security requirements: CMMC enforcement begins in November 10, 2025, and few organizations feel truly ready. In a recent industry survey, only 1% of contractors said they’re confident they could pass an audit today. 

On the other is a call for more technology—more cloud, more automation, more AI, more connected systems. When senior defense leaders call for “more AI in everything,” that also means more data to protect and larger attack surfaces to secure.

Even if you feel confident about your digital security and how you’re preparing for CMMC, with so much going on, it’s easy to stumble. 

Take FedRAMP 20X Moderate ATOs, for instance. 

We’ve been hearing from contractors who assume FedRAMP 20X will also satisfy CMMC cloud requirements. It won’t.

We’ve been hearing from contractors who assume that this new program, designed to speed up cloud authorizations and increase available technologies for the federal government, will also satisfy CMMC cloud requirements. It won’t.

Coalfire® analysts have been following FedRAMP’s modernization closely and have already flagged that the proposed 20X moderate designations don’t meet the DoD FedRAMP equivalency memo or CMMC’s cloud bar. 

That kind of nuance will make or break compliance, but you won’t find it with an LLM or a chatbot. 

If you want to make sure, you’re taking the right steps to secure your business, you need to make sure you’re taking directions from people who understand the landscape like the backs of their hands. 

What FedRAMP and 20X Really Mean for Contractors

FedRAMP has never been a static checklist, and the pace of recent changes has made it difficult for the average cloud service provider to keep up. Do the new automation pilots change what evidence is required, how it’s delivered, how it’s evaluated? If so, how soon? If your cloud provider is “in process,” or “FedRAMP Ready” does that cover your organization, or will you be exposed in a CMMC audit? 

Coalfire has long been at the center of FedRAMP as a Third-Party Assessment Organization (3PAO). Having supported FedRAMP authorizations for both large cloud providers and new SaaS entrants, we’ve helped teams through these exact questions:

Yes—automation will eventually standardize how evidence is packaged and submitted using OSCAL, but most agencies today still expect traditional documentation alongside machine-readable files. The tools are modernizing faster than the process.

No—those designations mean a provider is pursuing FedRAMP authorization, not that it meets it. For CMMC, only fully authorized or “FedRAMP Moderate Equivalent” environments qualify for handling Controlled Unclassified Information (CUI).

One thing we’ve been seeing lately is that while initiatives like FedRAMP 20X and OSCAL aim to make compliance faster and more predictable, they also end up shifting more responsibility onto the contractors who depend on those systems. The result is more moving parts which can actually make compliance harder to achieve and maintain.

The organizations that keep momentum are the ones that align their FedRAMP and CMMC efforts early. They treat evidence as a shared asset. Documentation lives alongside development, and compliance checks happen continuously instead of at the finish line.

Experience across both frameworks has shown us that success depends as much on timing, translation, and coordination as it does on tools. During the FedRAMP 20X low pilot in 2025, Coalfire worked alongside Paramify to combine automation and advisory oversight—helping teams cut documentation effort while staying aligned with evolving PMO expectations. That same approach informs our RAMP/pak starter toolkit, which dozens of cloud vendors now use to simplify preparation and keep projects on track.

Every shortcut in compliance is bound to add a little more work somewhere else. The trick is knowing where. Coalfire maintains a 100% acceptance rate on FedRAMP packages we build for clients. Read how.

Where FedRAMP Meets CMMC

FedRAMP and CMMC share DNA, but that overlap is often misunderstood. 

CMMC Level 2 requirements trace back to NIST 800-171, while FedRAMP is rooted in NIST 800-53. Controls around access management, logging, and incident response line up, but you can’t just copy and paste your FedRAMP scope, boundary, and evidence into a CMMC package. Just ask any contractor who’s tried to reuse FedRAMP documentation without professional guidance. Most find themselves duplicating effort or missing gaps entirely. 

Experience matters here. Compliance demands a thorough understanding of the ever-changing legal and technical landscapes and how everything works together. 

Controls around access management, logging, and incident response line up, but you can’t just copy and paste your FedRAMP scope, boundary, and evidence into a CMMC package.

For instance, not all authorizations translate. Under DoD rules, only FedRAMP-authorized and FedRAMP Moderate Equivalent environments count for processing CUI. That means a cloud service offering with a FedRAMP Rev5 Moderate ATO can strengthen a contractor’s compliance case. But assuming the new FedRAMP Moderate 20X carries the same weight? That can be a costly mistake.

Coalfire has seen mid-tier contractors assume their vendor’s “FedRAMP in process” or “FedRAMP Ready” label meant coverage for CMMC, only to learn later it didn’t, leading to months of additional remediation to stay eligible for contracts. 

How do you avoid this? 

Coalfire works with contractors to align scopes and boundaries. Together we map evidence across frameworks, reuse what truly applies, and identify where fresh work is needed. Our teams connect FedRAMP and CMMC controls in context—linking the evidence, environments, and expectations that too often live in silos. That orchestration turns overlapping requirements into a single, workable strategy.

CMMC Challenges That Trip Up Contractors

As one of the first and most experiencedCertified Third-Party Assessment Organizations (C3PAOs), Coalfire Federal has conducted a lot of readiness assessments for businesses throughout the supply chain, and we see a handful of sticking points pop up again and again:

• Loosely defined scope, leaving CUI systems out of bounds.
• Confusion about external service providers (ESPs)—do they count as true managed service providers (MSPs)? Or are they required to meet cloud service provider (CSP) requirements equating to FedRAMP?
• Inconsistent encryption, especially across business units.
• Weak vendor oversight, with subcontractors unable to prove they’re meeting requirements.

Most of these issues trace back to gaps in ownership. If security, IT, and operations teams each treat compliance as someone else’s problem, evidence gets scattered across systems and vendors. Coordination gives you control and ensures everyone is aligned in their actions.

This makes it sound easy—and it can be. But only once you’re aware of it. Lock scope and ownership early. Build compliance into the way people already work. Once teams treat coordination as part of their security fabric, compliance will feel less like a game of telephone and more like having your ship together. 

One Partner for Both Frameworks

FedRAMP and CMMC aren’t separate tracks that contractors can manage in silos. They intersect on the same systems, controls, and evidence, so treating them as independent efforts almost guarantees duplication or missed gaps. The contractors who get ahead are the ones who understand where the frameworks align and where they diverge, and who invest in guidance that keeps those lines clear.

With experience across both frameworks (FedRAMP, as an accredited 3PAO, and a C3PAO for CMMC), Coalfire helps contractors reuse evidence where it counts so they approach audits with confidence. In an environment where security demands and innovation pressures keep colliding, that kind of clarity is what lets organizations keep moving forward.