In This Article
CR26 is FedRAMP's Consolidated Rules for 2026, in effect since July 4, 2026. CR26 replaces most of the old Rev 5 documentation set with five new deliverables.
Paramify generates all new CR26 deliverables: the Trust Center, the Security Decision Record (SDR), vulnerability detection and reporting, Significant Change Notifications (SCN), Ongoing Certification Report (OCR), Certification Package Overview (CPO), and the workspace where 3PAOs and agencies run your assessment.
Here's what CR26 requires, where Paramify handles it today, and what changed this year.
TL;DR
- CR26 replaced narrative, point-in-time FedRAMP documentation with five deliverables that update continuously, not annually.
- Trust Center, Security Decision Record (SDR), Vulnerability Detection & Response / Evaluation & Reporting (VDR/VER), Significant Change Notification (SCN), and CPO are all available in Paramify.
- FedRAMP Notice NTC-0014 made VDR/VER mandatory for every FedRAMP-certified CSP, Rev 5 included, by December 7, 2026. Certifications become revocable for non-compliance after March 7, 2027.
- Of the five deliverables, only CPO requires someone outside your organization — a 3PAO or federal agency. Everything else is a tooling and process problem you can solve in-house.
Which deliverables does CR26 actually require?
The SDR is only half of what used to be your SSP. CR26 splits the narrative System Security Plan into two documents: the Certification Package Overview, a short structured summary of your offering, and the SDR, which carries the control-by-control evidence.
→ Go deeper on SDRs: FedRAMP SDRs vs SSPs: What's the Difference and Why Should You Care?
→ Go deeper on vulnerability reporting: FedRAMP Notice NTC-0014 and the VDR Mandate
Who has to comply with CR26?
Anyone holding or pursuing FedRAMP Certification, on either track. If you're moving to 20x, all five deliverables apply directly. If you're staying Rev 5-certified, CR26 is still required.
That's now true in an especially concrete way for VDR/VER. Those rules originally let Legacy FedRAMP systems opt in.
FedRAMP Notice NTC-0014, issued in June 2026 in response to CISA's Binding Operational Directive 26-04, made VDR/VER mandatory for every certified CSP — Rev 5 included — by December 7, 2026.
Miss it, and your certification becomes revocable starting March 7, 2027.
What do CR26 deliverables require in practice?
A few of the cadences and definitions are stricter than they look on first read:
Vulnerability data has a 14-day clock, and "internet reachable" doesn't mean what you'd assume.
Machine-readable historical vulnerability activity has to be available for automated retrieval at least every 14 days, with a human-readable summary at least monthly.
Under the current VDR standard, "internet reachable" means an unauthenticated user on the public internet can reach the device — a firewall, gateway, or login screen in front of it doesn't change that classification.
A vulnerability not fully remediated within 192 days of evaluation has to be formally categorized as an accepted vulnerability, with documentation, not just left open on a list.
Remediation windows now scale with actual risk, instead of a flat CVSS score.
VDR assumes an exploit is automatable by default unless you can prove otherwise, and pairs that with a 1–5 pain scale.
At Class C (Moderate), a pain-level-5 finding — likely exploitable and internet reachable — gives you 2 days to respond. A pain-level-3 finding gives you 16. That's the shift NTC-0014 is enforcing: monthly scans and CVSS-only triage are explicitly called out as insufficient.
The SDR and CPO replace static SSPs with continuous truth.
Traditional Rev 5 SSPs relied on static, annual text documents that described an intended state. Under CR26, the SDR and CPO shift your security documentation into a continuously maintained, machine-readable record.
While control execution runs continuously in your pipelines and infrastructure, the SDR captures that live operational status and persistent verification data. Depending on your Certification Class, the underlying package schema is dynamically maintained on short, recurring cycles—from monthly (Class B) down to weekly (Class D). Powered by Paramify's structured data engine, your SDR exposes this real-time evidence to assessors and customer agencies, while seamlessly outputting human-readable SSP formats whenever required.
SCN replaced the SCR.
A change to your system waited on an agency sponsor's review under Rev 5 with the Significant Change Request (SCR) form. Instead, CR26 requires you to notify FedRAMP through the SCN process instead — the structure can flex to how you already track changes internally, but the notification itself isn't optional.
What mistakes do teams make with CR26?
Assuming VDR/VER is still a 20x-only concern.
It isn't, as of NTC-0014. A Rev 5 CSP with no plans to move to 20x is still on the hook for the December 7, 2026 deadline.
Treating CR26 as a renamed Rev 5 packet.
CR26 isn't the same documents with new labels. A team that plans to update its SDR annually, the way it updated its SSP, will be out of compliance the moment FedRAMP checks the timestamp.
Assuming the Trust Center is optional.
It's the mandated evidence-sharing channel, not a marketing nice-to-have.
How does Paramify provide CR26 deliverables?
Paramify was the first GRC platform to achieve FedRAMP 20x Class C (Moderate) Certification, and we used our own platform to get there.
The Paramify platform pulls evidence from your production systems (AWS, Okta, CrowdStrike, and similar) through APIs rather than manual review, the same structured data source produces your SDR, CPO, VDR/VER reporting, and SCN in human and machine-readable forms. Seamlessly publish them to your Trust Center, powered by Paramify.
For the VDR/VER mandate specifically, Paramify flags Likely Exploitable and Internet-Reachable vulnerabilities as they're detected, so your team can prioritize the pain-level-5 findings instead of sifting through raw scanner output, and keeps that data tied to your SSP and POA&M in one place.
→ Learn, in depth, how Paramify automates evidence collection, validation, and issue creation or watch the video below:
Meet your CR26 deadlines with Paramify.
CR26 replaced a once-a-year documentation exercise with five deliverables that update on their own schedule — some as often as every 14 days, and one now on a hard December deadline that applies to every certified CSP.
Paramify automates all five today: Trust Center, SDR, VDR/VER, SCN, and the workspace 3PAOs and agencies use to run IVV.
If you're evaluating where you stand: read the full breakdown of FedRAMP Notice NTC-0014 and the VDR mandate to see if the December deadline applies to you, check how Paramify's Trust Center meets the CR26 evidence-sharing requirement, or request a demo to see the VDR/VER automation against your own environment.
FAQ
What is CR26?
CR26 is FedRAMP's Consolidated Rules for 2026, in effect since July 4, 2026. It replaces most of the old Rev 5 documentation with five deliverables that update continuously instead of annually.
Is CR26 the same thing as FedRAMP 20x?
No. CR26 is the underlying rule set; 20x is the certification program built around it. Rev 5-certified providers who haven't moved to 20x are still subject to the applicable CR26 deliverables.
Do I need to worry about CR26 if I'm staying on Rev 5?
Yes. CR26 doesn't exempt providers maintaining Rev 5, and as of FedRAMP Notice NTC-0014, the VDR/VER deliverable specifically now applies to every certified CSP regardless of track.
What is FedRAMP Notice NTC-0014?
NTC-0014 is FedRAMP's June 2026 response to CISA's Binding Operational Directive 26-04. It made the VDR and VER rulesets, previously optional for Legacy FedRAMP, mandatory for every certified CSP by December 7, 2026, with certifications becoming revocable for non-compliance starting March 7, 2027.
Does CR26 apply if my company is still on FedRAMP Rev 4?
Rev 4 was retired in 2023 and isn't a recognized CR26 track. A Rev 4 account is treated the same as pursuing a net-new Certification.
What replaced the System Security Plan (SSP) under CR26?
The narrative SSP is split into two documents: the Certification Package Overview, a short structured summary, and the Security Decision Record, which carries the control-by-control evidence.
What's the difference between an SDR and an SSP?
An SSP describes what you intend to implement, reviewed periodically. An SDR reflects what your controls are actually doing, updated in real time and delivered in machine-readable form alongside a human-readable SSP-format output.
Is the Trust Center optional?
No. It's the required channel for sharing certification data with agencies, and CR26 specifically governs how agency access-denial has to be handled.
How often does vulnerability data need to be updated under CR26?
Machine-readable historical vulnerability data has to be available for automated retrieval at least every 14 days, with a human-readable summary at least monthly.
What counts as "internet reachable" under the VDR standard?
Any device an unauthenticated user on the public internet can reach, even indirectly. A firewall, gateway, or authenticated login screen in front of it doesn't change that classification.
What counts as an "accepted vulnerability" under VDR?
Any vulnerability not fully mitigated or remediated within 192 days of evaluation has to be formally categorized as accepted, with supporting documentation.
Who can perform the Independent Verification & Validation (IVV) assessment?
A FedRAMP-recognized 3PAO or a federal agency. It's the one CR26 deliverable that legally can't be done entirely in-house. The results of that assessment are used to populate the CPO (Certification Package Overview).
What triggers a Significant Change Notification (SCN)?
A significant change to your system or control implementation. SCN replaces the old agency-sponsor review process — you notify FedRAMP instead of waiting for sponsor approval.
What's the deadline for VDR/VER compliance specifically?
December 7, 2026, for every FedRAMP-certified CSP. Certifications become revocable for non-compliance starting March 7, 2027.
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