KSIs vs. NIST Controls in FedRAMP 20X – What’s Changed?

FedRAMP 20X’s KSIs are meant to simplify compliance for cloud providers. Learn which controls are excluded from NIST 800-53, what’s added, and how a risk-based approach with Paramify simplifies your transition to this cloud-native, flexible framework.

Isaac Teuscher
|
53
min read

In This Article

A lot of people are curious how the new FedRAMP 20X KSIs relate to NIST control families (NIST 800-53, NIST 800-171, etc).

FedRAMP 20X is meant to simplify federal cybersecurity compliance. But, since KSIs aren’t directly tied to NIST controls, some worry that it will add extra work and control mappings.

Let’s set your mind at ease. Here we’ll explain what a KSI is, break down the differences between a KSI and control, and show where there are differences between the 20X KSIs and NIST families, so you can know what to expect moving forward 

What is a KSI? 

A KSI is a Key Security Indicator. This is a measurable metric or control used to assess the security posture of cloud services in FedRAMP. 

KSIs are designed to provide a standardized, machine-readable, way to evaluate and monitor the security of a CSPs by focusing on critical security controls or outcomes. 

How is a KSI Different from a Control?

Traditional NIST 800-53 controls can be complex and broad. KSIs aim to simplify and streamline security assessments by targeting specific, high-impact security indicators that are easier to automate and validate.

KSIs are part of FedRAMP’s modernization efforts to make security assessments more efficient, scalable, and cloud-native. 

They focus on measurable outcomes (e.g., system uptime, patch management compliance, or incident response times) rather than prescriptive processes to give CSPs more flexibility in how they demonstrate compliance.  

20x KSIs vs 104 selected 800-53 controls

The FedRAMP PMO has made it clear that the 20X KSIs will not just be an abstraction layer on top of NIST 800 controls.

KSIs are meant to show capabilities and provide flexibility for CSPs.

But, KSIs also have “related controls” that show how they may relate to NIST controls. 

FedRAMP 20X is currently in the pilot phase for FedRAMP Low.

It can be a useful exercise to compare the current FedRAMP Low baseline requirements (NIST 800-53 selected controls) to the 20X KSI “related controls” to see what the focus of 20X requirements are from a NIST control lens.

When we dig into the related controls a few key insights emerge.

NIST 800-53 Rev 5 Controls Excluded from FedRAMP 20X

Which NIST 800-53 Rev 5 Controls for FedRAMP Low are excluded from the FedRAMP 20X KSI “related controls”?

NIST 800-53 Rev 5 Controls Excluded from FedRAMP 20x KSI “Related Controls”
Control Family Excluded Controls
Access Control (AC) AC-8, AC-18, AC-19
Awareness and Training (AT) AT-1, AT-2(2), AT-4
Audit and Accountability (AU) AU-5, AU-6
Security Assessment and Authorization (CA) CA-2, CA-2(1), CA-5, CA-6, CA-7, CA-7(4), CA-8
Configuration Management (CM) CM-5
Contingency Planning (CP) CP-3
Identification and Authentication (IA) None excluded
Incident Response (IR) IR-2
Maintenance (MA) All excluded
Media Protection (MP) All excluded
Physical and Environmental Protection (PE) All excluded
Planning (PL) PL-4, PL-4(1), PL-8, PL-10, PL-11
Personnel Security (PS) PS-6
Risk Assessment (RA) RA-2
System and Services Acquisition (SA) SA-4(10)
System and Communications Protection (SC) SC-15, SC-20, SC-21, SC-22
System and Information Integrity (SI) SI-12
Supply Chain Risk Management (SR) SI-11(1)

Notes:

  • Control Families with "All Excluded": For Maintenance (MA), Media Protection (MP), and Physical and Environmental Protection (PE), all controls within these families are excluded from the FedRAMP 20x KSI “related controls.”
  • No Exclusions: The Identification and Authentication (IA) family has no controls excluded.
  • Source Context: This table reflects the exclusions specific to the FedRAMP 20x initiative’s KSI framework, which focuses on streamlined, high-impact security indicators for low-impact systems as part of FedRAMP’s modernization efforts.

Learn more: CISA Secure Software Development Attestation Form

Which NIST 800-53 Rev 5 Controls that are 20x KSI “related controls” are added to existing FedRAMP Low controls?

Access Control (AC)
AC-23 Employ [Assignment: organization-defined techniques] for [Assignment: organization-defined data storage objects] to detect and protect against unauthorized data mining.
Awareness and Training (AT)
AT-6 Provide feedback on organizational training results to the following personnel [Assignment: organization-defined frequency]: [Assignment: organization-defined personnel].

What Fewer KSIs Means for Your Security Program 

KSIs are reducing and simplifying the control set for FedRAMP. 

There are a lot more controls removed than added (as you can see above). 

Some NIST control families like Maintenance (MA), Media Protection (MP), and Physical and Environmental Protection (PE) which are included in the FedRAMP Low Baseline, are completely excluded from 20x KSIs.  

This is good news for CSPs and it’s possible because the KSIs are Cloud Native. A cloud service offering will already inherit most controls in these families from their LaaS providers (AWS, Azure, GCP, etc). 

The change to KSIs is meant to give you flexibility that wasn’t possible with the required detail and rigidity of NIST controls.

KSIs are Simple With Risk-Based Security

KSIs shouldn’t be seen as a new set of requirements. They are based on NIST FedRAMP baselines but modernized for cloud native offerings and condensed to focus on capabilities.

If you’re concerned about updating your security program, it all boils down to this: 

If you do risk management and have secure practices you will be fine.

When you manage risk effectively any control standard will be easy to assess because you have made risk-based decisions to protect your assets, processes and people. 

Paramify’s risk solutions focus on managing risk first. We’re participating in the FedRAMP phase 1 pilot to get a first-hand look at what’s changing with FedRAMP 20X. We’ll stay up to date on changes, so you can know your security program meets compliance requirements no matter what changes. 

Prepare for FedRAMP 20X

Implementing a risk-based security approach is simple when you use Paramify. You can even build the majority of your security strategy in just 45 - 60 minutes

Have questions? Please reach out — our team loves to help. 

Sign up for free demo of Paramify below, or request a demo video, to start preparing for FedRAMP 20X today: 

What does Paramify do?

Risk-based vs compliance-based security: Here's the difference

How automation can improve your security program

Isaac Teuscher
A Security Engineer leading the technical implementation of cloud and AI-driven security. With experience in NIST 800-53 and FedRAMP, Isaac collaborates with executive teams to build scalable security programs that meet the highest federal compliance standards.
May 2025
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Frequently Asked Questions

Can compliance advisors or consultants work in Paramify with us, and does it help with managed-service models?

Absolutely. Paramify is used by many advisory partners, RPOs, and MSPs to guide, generate, and manage documentation, perform gap assessments, facilitate policy/procedure drafting, and oversee remediation activities. Advisors can fill out templates, manage controls, and generate client-ready documents.

We have privacy or compliance concerns, can we restrict what external reviewers can access?

Yes, you can assign role-based access controls in Paramify. Advisors or auditors can be given access only to certain programs, assessment and their related evidence.

Sensitive information can be withheld or redacted as needed, and only authorized reviewers see specific items.

Can auditors or advisory partners get direct access to our Paramify environment, or do we have to export everything for them?

Yes, Paramify allows external assessors/auditors and advisors to be invited as users, with controlled permission levels. They can review specific evidence, policies, SSPs, POA&Ms, or assessment modules without accessing broader company data. 

Documentation — such as Appendix A, SSPs, procedures, and POAMs — can also be exported in multiple standard formats (Word, Excel, OSCAL, EMASS, PDF) as needed.

Can I get matched with an Advisor based on my specific needs?

Yes. You can use the Get Matched feature on our website. We will review your specific compliance goals and connect you with the partner best suited for your industry and timeline.

How do Advisors use Paramify during a FedRAMP engagement?

Advisors use Paramify to conduct Gap Assessments, map controls, Automate SSPs, and manage POA&Ms.

Instead of spending months writing Word documents, the Advisor inputs the system architecture and control implementations into Paramify, which then generates the required NIST-formatted documentation.

Does Paramify compete with its Advisors?

No. Paramify is a software company. We do not offer independent audit or long-term consulting services. Our goal is to empower Advisors with better tools so they can serve more clients effectively.

What are the different partner tiers?

We feature Premier Partners prominently on our site. These are firms that have demonstrated a high level of proficiency with the Paramify platform and have successfully helped many clients through the authorization process using our tools.

How do I become an official Paramify Advisor Partner?

We look for firms with a proven track record in federal compliance. If you are interested in joining our network and leveraging our automation products, you can reach out via our contact page or schedule a demo to see how our tools fit into your workflow.

What is the benefit of using an Advisor who uses Paramify vs. one who doesn't?

Advisors using Paramify can accelerate your implementation and typically deliver documentation in a fraction of the time it takes without Paramify. This means:

  • Faster Implementation: An accelerated implementation roadmap keeps timelines predictable.
  • Lower Costs: Reduced manual consultant hours.
  • Higher Accuracy: Automation eliminates the "copy-paste" errors common in traditional SSPs.
  • Easier Maintenance: Your Advisor can help you manage POA&Ms and continuous monitoring within the platform.
Does working with an Advisor on this list guarantee FedRAMP or CMMC authorization?

No firm can "guarantee" authorization, as the final decision rests with the government authorizing body (e.g., the FedRAMP PMO or the DoD).

However, working with a Paramify Advisor significantly reduces the risk of documentation errors and ensures your package is built on a technically sound, automated foundation.

How do I choose the right Advisor for my organization?

Our Advisor page allows you to filter partners by their specific expertise, such as FedRAMP, CMMC, FISMA, or GovRAMP.

Why does Paramify partner with Advisors?

Paramify is an “Iron Man suit” for GRC experts. We provide automation technology to generate and manage compliance documentation (like SSPs snd POA&Ms) while Advisors provide the expert human oversight and implementation expertise.

Together, we offer a "best-of-both-worlds" solution: expert consulting powered by industry-leading automation and risk management planning.

What is the Paramify Advisor Partner Network?

The Paramify Advisor Partner Network is a curated group of cybersecurity and compliance firms — including CMMC Registered Practitioner Organizations (RPOs) and accredited 3PAOs — that use Paramify’s platform to deliver faster, more accurate compliance outcomes for their clients.

I already have an advisor or very capable GRC team. Why do I need Paramify?

Use Paramify's Risk Solution platform to automate ATO packages, improving cost efficiency, speed, and accuracy. This frees your team to focus on more valuable efforts like security posture enhancement and compliance improvements.