FedRAMP 20x 3 min read

    Can we run a FedRAMP gap analysis ourselves?

    Yes. A company's own team can run a FedRAMP gap analysis, the review of how far its cloud product is from meeting the requirements of FedRAMP, the U.S. government's security program for cloud software. The team has access to all the official guidance it needs to reach certification. The trade-off is time and accuracy: FedRAMP is far more nuanced than commercial security standards such as SOC 2 or ISO 27001, and FedRAMP itself says that companies new to the program "will almost always benefit" from a high-quality advisor.

    The common options:

    Teams usually choose one of three routes for a gap analysis, or combine them:

    Option
    In-house, in a spreadsheet
    Strengths
    No fees, and the team learns FedRAMP as it goes
    Trade-offs
    FedRAMP is far more nuanced than SOC 2 or ISO 27001, so the work often takes months, answers can be wrong, and many efforts end with hiring a consultant anyway
    Option
    Consultant
    Strengths
    Deep FedRAMP expertise and credibility
    Trade-offs
    Typically takes weeks of workshops; the result is often a static spreadsheet with high-level advice, and the expertise leaves when the engagement ends
    Option
    General-purpose AI, such as chat assistants
    Strengths
    Fast and capable at analysis
    Trade-offs
    Learns from general, publicly available information, so it still needs someone with FedRAMP experience to check the results

    Why AI alone isn't enough:

    General-purpose AI tools learn from general, publicly available information, not from hands-on experience getting products through FedRAMP. Someone with real FedRAMP experience still needs to check what goes into the AI and what comes out, catch mistakes and turn the results into concrete next steps. Paired with that expertise, AI can speed up the work a great deal.

    What it costs:

    NYLE estimates that FedRAMP consultants typically charge $300 to $400 an hour, and that for the most demanding certification level, a consultant-led gap analysis can run well into six figures. These are NYLE's estimates, not FedRAMP figures. Gap analysis software is a lower-cost route: NYLE Gap Analysis costs $25,000 per project for 12 months, covers all four certification classes (A to D) with no add-ons, and offers a free 30-day trial that includes a full Class A gap analysis.

    Who stays responsible:

    Whichever route a team takes, the company itself remains responsible for the result. FedRAMP does not provide tools, guidance, advice or support for this work; private companies offer those instead. FedRAMP's rules make the company responsible for the accuracy of its certification package, the set of documents FedRAMP and federal agencies review, including any parts prepared by advisors or software. An advisor who claims it will produce the company's documents and evidence and meet FedRAMP's ongoing requirements on the company's behalf is a warning sign.

    Sources

    1. FedRAMP.gov: Finding an Advisor
    2. FedRAMP.gov: Do the Work
    3. FedRAMP.gov: FedRAMP Certification (20x rules)
    4. NYLE Gap Analysis