FedRAMP Compliance Consulting

Readiness for FedRAMP Certification under the Consolidated Rules for 2026, on the Rev 5 or 20x path: scope, controls, machine-readable packages, and the Ongoing Certification work that keeps you certified.
Contact us
Definition

What is FedRAMP?

FedRAMP is the federal program that certifies cloud services for use by agencies. Under the Consolidated Rules for 2026 (CR26), in effect since July 4, 2026, a provider earns a FedRAMP Certification on one of two types: Rev 5, which documents NIST SP 800-53 controls in a Security Decision Record, or 20x, which proves Key Security Indicators with automated, machine-readable evidence. FedRAMP certifies the cloud service, and each agency still issues its own Authorization to Operate before it uses it. FedRAMP stops accepting new Rev 5 applications on June 11, 2027, and existing Rev 5 certifications remain active until at least December 31, 2028.
CR26 replaces the Low, Moderate, and High impact levels with certification classes. Class A, available on 20x, covers most non-sensitive use cases and needs 7 Key Security Indicators plus a SOC 2 Type II, GovRAMP, or Rev 5 assessment from the past 12 months. Class B covers most Low security objectives and Class C most Low and Moderate objectives, and both need an independent assessment by a FedRAMP Recognized assessor. Class D covers most use cases regardless of security objective and is available only on Rev 5 today. The CR26 Rev 5 baselines carry 155 controls for Class B, 322 for Class C, and 409 for Class D.
Services

BD Emerson's FedRAMP readiness services

We prepare cloud service providers for FedRAMP Certification on either type. Your team owns the program and a FedRAMP Recognized assessor performs the assessment. We help you scope it, build it, and prove it works before the assessor and FedRAMP review it.
Gap assessment against your target profile
Rev 5 control implementation and CR26 updates
20x readiness and KSI engineering
VDR and VER readiness
Ongoing Certification support

Gap assessment against your target profile

We assess your cloud service offering against the certification profile you are targeting, meaning the type, path, and class, and against the rules that come with it: the Rev 5 control baseline for your class, or the Key Security Indicators and provider rules for 20x. The result is a prioritized remediation plan tied to rule IDs, so every gap has an owner and a closing condition.

Rev 5 control implementation and CR26 updates

For Rev 5, we design and implement controls against the CR26 baselines and bring the package up to the new rules: JSON documents in place of Word and Excel templates, a Minimum Assessment Scope in place of the legacy boundary, persistent vulnerability detection, accepted-vulnerability reporting in place of POA&Ms, and notification-based significant change management.

20x readiness and KSI engineering

For 20x, we design KSI measures with your engineers, review the validation code and the JSON your pipelines generate, and help you publish the Certification Package Overview and Security Decision Record through a FedRAMP-compatible trust center. Our FedRAMP 20x readiness service covers this path in detail.
More

VDR and VER readiness

The Vulnerability Detection and Response and Vulnerability Evaluation and Reporting rulesets become required for every Class B, C, and D provider on December 7, 2026. We help you put persistent detection in place, rate each finding for exploitability, internet reachability, and potential agency impact, work to FedRAMP's remediation timeframes, and produce the monthly activity report.

Ongoing Certification support

Certification starts the recurring work: persistent vulnerability detection and monthly reporting, machine-based resources validated monthly on Rev 5 and every 7 or 3 days on 20x, a current package, the Ongoing Certification Report every three months, and the annual independent assessment. We help your team run that cadence with your own tooling.
Expertise

What changes under CR26, and what we build

The Consolidated Rules for 2026 changed what FedRAMP asks for on both types. We build the capabilities the new rules require once, to the 20x standard, so a Rev 5 provider can reuse them when it moves to 20x.
01

Package overview and decision record

The Certification Package Overview and Security Decision Record take the place of the System Security Plan. We help your team structure both in human-readable and JSON form, in the GRC platform you run, including Vanta or Paramify, and check the output against FedRAMP's published schemas.
02

Minimum Assessment Scope

Every information resource likely to handle federal customer data is in scope, along with its information flows and each third-party service the offering depends on. We draw the scope with your architects before control work starts.
03

Accepted vulnerabilities

CR26 eliminates the POA&M. A vulnerability not fully mitigated or remediated within 192 days of evaluation must be categorized as an accepted vulnerability, and we help you set up the tracking and reporting FedRAMP expects.
04

Significant change notifications

Changes are sorted into routine recurring, adaptive, or transformative, with notices sent on FedRAMP's timelines, including 30 and 10 business days before a transformative change and 5 after. We set up the process and the templates behind it.
05

Trust center and data sharing

Certification data moves to a FedRAMP-compatible trust center with documented programmatic access and access logging. We help you configure one and connect it to the systems that generate your package.
06

Assessor independence

An assessor may not assess an offering within two years of advising on it, so we stay on the advisory side. We are not a FedRAMP Recognized assessor, and we recommend Schellman for the assessment.
contact us

Planning a FedRAMP Certification?

Speak with BD Emerson about your certification profile, your December 7, 2026 VDR and VER deadline, and whether Rev 5 or 20x fits your offering.
Our Advantage

Why BD Emerson for FedRAMP

Current with the 2026 rules

We work from FedRAMP's machine-readable rules dataset and cite rule IDs in every gap and recommendation, so your plan tracks what FedRAMP publishes, including each revision.

Engineering-led delivery

FedRAMP's own guidance says the most successful 20x pilots were led by engineering and product teams. Our consultants work alongside your engineers on the measurements, and your compliance staff own the rule mapping and the package.

One firm for the adjacent work

SOC 2 readiness, FedRAMP penetration testing, and CMMC sit in the same firm, so the evidence you build for one program carries into the next.
Reviews

What our customers say

Great consulting firms for scaling security, compliance, and appsec.

Outstanding partner in Technical and Cyber Due Diligence

Appsec maturity and application hardening.

BD Emerson helped us simplfiy our compliance management.

BD Emerson did such a phenomenal job. What started as privacy support quickly became a full partnership across compliance, engineering, and even business operations. They’re embedded with our team. They understand our product. They move fast. They’re simply invaluable.

Adam Ben Jacobs

CTO @ OneStep GPS

Great consulting firms for scaling security, compliance, and appsec.

Outstanding partner in Technical and Cyber Due Diligence

Appsec maturity and application hardening.

BD Emerson helped us simplfiy our compliance management.

BD Emerson did such a phenomenal job. What started as privacy support quickly became a full partnership across compliance, engineering, and even business operations. They’re embedded with our team. They understand our product. They move fast. They’re simply invaluable.

Adam Ben Jacobs

CTO @ OneStep GPS

We had a hard time finding the right company to partner with in support of our compliance journey. Some vendors sell the idea that they do the work, but then you end up doing everything. The ambiguity is what killed our last project. BD Emerson’s team has such great technical knowledge and understands the standard so well that they made us comfortable with moving fast. This has led to us closing major enterprise customers that were previously out of reach because of security and compliance.

Tom Watkins

CEO @ AMI AssetTrack

Lead an enterprise initiative to overhaul the organization's technology stack from ecommerce, corporate tech, and corporate security.

Supported ISO 42001 exercise and served as internal auditor.

Rubrik's privacy and compliance team began with the backbone of BD Emerson. BD Emerson supported building out the privacy program, GRC (ISO 27001, SOC 2, CMMC, FedRAMP), and the appsec function.

We needed a partner who could move quickly, without sacrificing precision. BD Emerson brought the expertise, structure, and speed we were looking for. Their team became an extension of ours, embedding themselves across the organization, guiding us step by step, and giving us confidence in areas we hadn’t tackled before. The internal audit they conducted was so detailed that even the external auditors called it out. Achieving ISO 27001 with zero nonconformities says everything you need to know about the quality of the partnership.

Walid Souilem

CTO @ FGI Worldwide

We had a hard time finding the right company to partner with in support of our compliance journey. Some vendors sell the idea that they do the work, but then you end up doing everything. The ambiguity is what killed our last project. BD Emerson’s team has such great technical knowledge and understands the standard so well that they made us comfortable with moving fast. This has led to us closing major enterprise customers that were previously out of reach because of security and compliance.

Tom Watkins

CEO @ AMI AssetTrack

Lead an enterprise initiative to overhaul the organization's technology stack from ecommerce, corporate tech, and corporate security.

Supported ISO 42001 exercise and served as internal auditor.

Rubrik's privacy and compliance team began with the backbone of BD Emerson. BD Emerson supported building out the privacy program, GRC (ISO 27001, SOC 2, CMMC, FedRAMP), and the appsec function.

We needed a partner who could move quickly, without sacrificing precision. BD Emerson brought the expertise, structure, and speed we were looking for. Their team became an extension of ours, embedding themselves across the organization, guiding us step by step, and giving us confidence in areas we hadn’t tackled before. The internal audit they conducted was so detailed that even the external auditors called it out. Achieving ISO 27001 with zero nonconformities says everything you need to know about the quality of the partnership.

Walid Souilem

CTO @ FGI Worldwide

BD Emerson didn’t just help us meet our compliance goals; they integrated security and privacy into the core of our operations. I highly recommend BD Emerson to anyone seeking SOC 2 or GDPR compliance, or simply looking to enhance their security team and boost customer trust in their product and services. Their dedication and expertise have been invaluable to our success.

Padraig Reilly

CEO, Boxcore

BD Emerson understood our business requirements and worked side-by-side with us. The policies and controls we developed together not only meet compliance standards but improve how we operate day to day.

Matt Meierdierks

IT Manager, Lincoln Industries

From day one, BD Emerson brought urgency, clarity, and a sharp understanding of what truly matters to our business — earning and keeping customer trust. They went beyond helping us meet compliance requirements; they helped build a foundation for secure, scalable growth. That kind of partnership is rare.

Jason Marker

CEO @ LifeLenz

BD Emerson didn’t just help us pass an audit—they helped us build a sustainable culture of security.

Alexey Indeev

CTO Spare

BD Emerson was essential in helping our company navigate the daunting process of leveling up our security infrastructure. BD Emerson’s impressive expertise and confidence throughout the process helped our team exceed HIPAA and SOC 2 Type 1 standards quickly, distilling what can be an overwhelming process into a streamlined, organized effort. From day one they began adding value and getting us on course. With their help we delivered on a massive security overhaul with both extreme efficiency and thorough attention to details. Because of BD Emerson’s support, we’ve increased our clients’ trust in Titan Intake and the life-changing work it accomplishes for those seeking specialist referrals.

Patrick Bruce

CEO, Titan Intake

BD Emerson didn’t just help us meet our compliance goals; they integrated security and privacy into the core of our operations. I highly recommend BD Emerson to anyone seeking SOC 2 or GDPR compliance, or simply looking to enhance their security team and boost customer trust in their product and services. Their dedication and expertise have been invaluable to our success.

Padraig Reilly

CEO, Boxcore

BD Emerson understood our business requirements and worked side-by-side with us. The policies and controls we developed together not only meet compliance standards but improve how we operate day to day.

Matt Meierdierks

IT Manager, Lincoln Industries

From day one, BD Emerson brought urgency, clarity, and a sharp understanding of what truly matters to our business — earning and keeping customer trust. They went beyond helping us meet compliance requirements; they helped build a foundation for secure, scalable growth. That kind of partnership is rare.

Jason Marker

CEO @ LifeLenz

BD Emerson didn’t just help us pass an audit—they helped us build a sustainable culture of security.

Alexey Indeev

CTO Spare

BD Emerson was essential in helping our company navigate the daunting process of leveling up our security infrastructure. BD Emerson’s impressive expertise and confidence throughout the process helped our team exceed HIPAA and SOC 2 Type 1 standards quickly, distilling what can be an overwhelming process into a streamlined, organized effort. From day one they began adding value and getting us on course. With their help we delivered on a massive security overhaul with both extreme efficiency and thorough attention to details. Because of BD Emerson’s support, we’ve increased our clients’ trust in Titan Intake and the life-changing work it accomplishes for those seeking specialist referrals.

Patrick Bruce

CEO, Titan Intake

Certificates

Our accreditations

Our practitioners hold security, privacy, cloud, and AI governance certifications, and the people who earned them do the work on your engagement.
FAQ

Frequently asked questions

Do cloud providers need FedRAMP to sell to federal agencies?

What changed with the Consolidated Rules for 2026?

Should we pursue Rev 5 or 20x?

How long does FedRAMP Certification take?

What is the December 7, 2026 deadline?

Do you perform the FedRAMP assessment?

Is OSCAL required?

Does a SOC 2 help with FedRAMP?

Blog

Related Articles

Insights on strategy, transactions, technology, security, and compliance from BD Emerson's practitioners