FedRAMP High

FedRAMP High is the most stringent of the three FedRAMP cloud authorization baselines, designed for federal systems containing high-impact data (loss of confidentiality, integrity, or availability would have severe or catastrophic effect).

FedRAMP impact levels

FedRAMP authorizations are categorized by FIPS 199 impact level: Low (loss has limited adverse effect), Moderate (serious adverse effect), and High (severe or catastrophic effect). Most federal SaaS authorizations are Moderate. High is reserved for systems containing sensitive law enforcement, financial, healthcare, or other high-impact data; loss of availability for an extended period could materially impair mission performance. The Moderate baseline maps to NIST 800-53 with 325 controls; High extends this to 421 controls.

What FedRAMP High requires beyond Moderate

FedRAMP High adds controls around supply chain risk management, system and information integrity (deeper malware protection), incident response (24x7 SOC requirement), audit logging (full session capture for privileged users in some scoping), and physical security (TS-cleared personnel for some operational tasks). The 3PAO (Third Party Assessment Organization) assessment is correspondingly deeper and more expensive. Few SaaS products carry FedRAMP High; AWS GovCloud, Azure Government, Google Workspace Federal, and a small set of others do.

Practical procurement

AI vendors selling to federal customers handling High-impact data must either (a) carry FedRAMP High themselves or (b) deploy on a FedRAMP High-authorized infrastructure (AWS GovCloud, Azure Government) and inherit applicable controls. Inheritance does not transfer all controls — the application-layer controls must still be implemented. Buyers should ask for the SSP (System Security Plan), the SAR (Security Assessment Report), and the POA&M (Plan of Action and Milestones) to understand what controls are implemented vs inherited vs deferred.