FedRAMP High

Data centers must implement and maintain all 421 security controls from NIST SP 800-53 Revision 4, including 109 baseline controls mandatory for high-impact systems plus additional controls addressing advanced persistent threats, advanced malware detection, and enhanced cryptographic protections.

Each control requires documented evidence of implementation, testing, and continuous compliance verification through automated tools and manual assessments.

Providers must establish automated continuous monitoring capabilities that provide real-time or near-real-time visibility into system security posture, including vulnerability scanning (weekly minimum for high-risk assets), malware detection, configuration management scanning, and log analysis.

ConMon requirements mandate integration of SCAP-validated vulnerability scanners, intrusion detection systems, and Security Information and Event Management (SIEM) platforms with minimum 90-day log retention and alerting on critical findings within 24 hours.

Data centers must undergo continuous authorization cycles with quarterly risk assessments, security control reviews, and evidence collection demonstrating ongoing compliance with the FedRAMP baseline.

Each quarterly assessment requires an independent assessment team to verify control effectiveness, document any control deviations or compensating controls, and validate remediation of previously identified vulnerabilities within defined timeframes (critical findings within 30 days).

All data at rest and in transit must be encrypted using NIST-approved algorithms (AES-256 for data at rest minimum, TLS 1.2 minimum for transport layer), with cryptographic key management meeting FIPS 140-2 Level 3 standards for hardware security modules.

Data centers must implement key escrow for recovery purposes, maintain segregated key management systems, and demonstrate cryptographic lifecycle management including key rotation, revocation, and destruction protocols.

Multi-factor authentication (MFA) is mandatory for all privileged access to federal systems, with requirement for hardware tokens or authenticator applications (not SMS-based).

Data centers must implement role-based access controls (RBAC) with privileged access management (PAM) solutions, enforce principle of least privilege, conduct quarterly access reviews, and maintain detailed access logs with accountability for all administrative actions on critical infrastructure components.

FedRAMP High systems require incident response plans with 24-hour breach notification capabilities, maintaining 72-hour incident reporting timelines to the Federal Incident Response Center (FIRsC) and relevant agencies.

Data centers must maintain forensics-ready log aggregation, preserve evidence chains for all security events, conduct post-incident reviews within 30 days, and demonstrate continuous refinement of incident response procedures through tabletop exercises and red team assessments.

Data center facilities must implement biometric access controls at all entry points, maintain 24/7 video surveillance with minimum 90-day footage retention, implement environmental monitoring (temperature, humidity, water detection) with automated alerts, and conduct quarterly security assessments of physical infrastructure.

Visitor access requires badging, escort protocols, and access logs with equipment inspection procedures for entry and exit to sensitive areas.

FedRAMP High requires comprehensive assessment and continuous monitoring of all software, hardware, and service providers within the supply chain, including mandatory software bill of materials (SBOM) tracking, vulnerability disclosure agreements, and vendor security assessment questionnaires.

Data centers must maintain contractual protections requiring suppliers to comply with FedRAMP requirements and enable direct assessment access for federal auditors, with particular scrutiny on foreign ownership, control, or influence (FOCI) restrictions.