FedRAMP High vs. FedRAMP Moderate: What’s the Difference?
Choosing between FedRAMP High and Moderate depends on data sensitivity, system boundary, and agency expectations. Learn how impact levels differ, what controls are required, and how to budget for each path.
FedRAMP offers different impact levels—Low, Moderate, and High—to match the sensitivity of data a cloud service processes. For organizations entering the federal market, understanding the distinctions between FedRAMP High and Moderate is critical for selecting the right path and allocating resources appropriately. This article compares the two levels by examining control requirements, cost implications, and operational considerations.
Data Sensitivity and Impact Levels
The primary difference between High and Moderate lies in the type of data each level protects. FedRAMP Moderate applies to systems that handle Controlled Unclassified Information (CUI), where a security breach could have a serious impact on an agency’s mission . FedRAMP High covers systems processing the government’s most sensitive unclassified data, where unauthorized disclosure could have a severe or catastrophic impact. As a result, High requires a greater number of controls, more stringent implementation, and deeper architectural segmentation to mitigate risk.
Control Requirements and Implementation
FedRAMP Moderate includes 325+ controls across families like access control, configuration management, and incident response . FedRAMP High expands on these with additional controls and heightened requirements, particularly around encryption, auditing, and security engineering. For example, High mandates more rigorous key management practices, stricter separation of duties, and advanced intrusion detection and prevention systems. Implementing these controls often necessitates specialized hardware, higher assurance cryptographic modules, and dedicated enclaves to isolate sensitive workloads.
Cost and Effort Differences
Higher security requirements translate into higher costs. Preparation costs for FedRAMP High can range from $150,000 to $500,000 , reflecting the need for advanced security architectures and controls. 3PAO assessments may cost between $250,000 and $500,000 . Annual maintenance for High impact systems typically ranges from $100,000 to $300,000 , compared to $75,000–$200,000 for Moderate . Additionally, High impact systems may require background checks and additional personnel vetting, contributing to higher operational overhead. The total cost of ownership for FedRAMP High can exceed $2 million over the lifecycle .
Authorization Timeline and Complexity
Given the increased number of controls, FedRAMP High assessments often take longer than Moderate. More time is needed to implement, document, and test the additional controls. However, the FedRAMP 20x initiative aims to streamline authorization timelines for all impact levels by leveraging automation and Key Security Indicators . Providers targeting the High level should closely monitor the 20x updates to capitalize on future efficiencies.
Choosing Between Moderate and High
When selecting an impact level, consider the type of data your service handles and the missions of your federal customers. If your system processes CUI or sensitive but unclassified data, Moderate may suffice. If you handle highly sensitive data—such as law enforcement information, healthcare records, or national security data—High is mandatory. Also assess your organization’s capacity to implement stringent controls and absorb higher costs. Some providers start with Moderate to establish a foothold in the federal market and later pursue High as they expand into more sensitive domains.
Conclusion
FedRAMP High and Moderate both enable cloud services to work with federal agencies, but they differ significantly in control requirements, cost, and complexity. Moderate is appropriate for many SaaS providers handling CUI, while High is designed for systems processing the government’s most sensitive unclassified information. Understanding these differences allows organizations to make informed decisions about which impact level aligns with their business goals and risk tolerance.