FedRAMP RFC-0024 Requires Machine-Readable SSPs: Convert to OSCAL the Easy Way

If you are currently authorized or seeking authorization, you likely have questions about timelines, definitions, and — most importantly — how to comply without hiring an army of consultants. Here we’ll provide the plain English breakdown of what is happening and how to convert to an OSCAL SSP quickly.

Why Require Machine-Readable Compliance Documentation?

The goal of RFC-0024 is to modernize the authorization process. FedRAMP wants to move from "human-written narratives" to machine-generated deterministic telemetry.

In simple terms, the government wants to stop reading creative writing assignments about your security posture and start ingesting actual data that proves your security posture. This shift is intended to speed up reviews, increase accuracy, and make interoperability between agencies easier.

But it also imposes strict new deadlines on CSPs.

Timeline to Convert to a Digital SSP

If you take nothing else away from this article, memorize these dates. Missing them has real consequences, ranging from public notification of non-compliance to revocation of your FedRAMP Certification.

April 15, 2026 — Final Requirements

FedRAMP publishes the final list of required machine-readable materials and approved formats (including OSCAL).

September 30, 2026 — Machine-Readable Docs Required

This is the day the requirement effectively kicks in.

New Authorizations: Must submit in machine-readable format. No exceptions.
Existing Authorizations: Must submit a full machine-readable package for your next annual assessment after this date.
Updates: Once you have switched to the new format, any 'significant change' must be updated in that format by the end of the following month.

September 30, 2027 — The Absolute Deadline.

If you haven’t transitioned by 2 PM ET on this day, existing certifications will be revoked.

What is "Machine-Readable" Documentation?

You will hear two terms thrown around a lot in this RFC. Here is what they actually mean for you:

1. Machine-Readable Authorization Data

This isn't just a PDF with text recognition. This refers to structured data formats (like JSON or XML) that a computer can process without human help. The industry standard for this is OSCAL. It allows different compliance tools to "talk" to each other without manual data entry.

2. Deterministic Telemetry

This is the gold standard FedRAMP is aiming for. It means verifiable data collected directly from your system — facts, not opinions.

Bad: A paragraph written by a human saying, "We use complex passwords."
Good: A machine-generated log directly from your config settings showing the exact password complexity rules currently active.

The Hard Way: Manual Conversion to Digital SSP

The "Chicken or the Egg" problem mentioned in the RFC acknowledges a painful truth: The industry hasn't adopted OSCAL widely because it’s hard to do.

Manually converting a 400-page System Security Plan (SSP) into JSON code is a nightmare. It is expensive, slow, and prone to "fat-finger" errors. If you try to retrofit your legacy Word documents into OSCAL by hand, you are looking at months of work for your GRC team — time they should be spending on actual security.

Plus, FedRAMP Rev 5 is massive. Maintaining consistency between your inventory, your diagrams, and your control implementations manually is nearly impossible.

The Easy Way: Automated OSCAL SSP with Paramify

This is exactly why we built Paramify. You shouldn't need a degree in XML to get a FedRAMP authorization.

While the government is mandating this shift now, Paramify has been generating machine-readable SSPs for hundreds of clients for years. Here is how we turn this RFC from a crisis into a simple checklist item:

1. Speed (Think Hours, Not Months)

We don’t manually type out JSON and neither should you. Simply provide your basic info in a short intake session, or upload your current SSP, and our platform generates the documentation.

We have seen companies generate a full ATO package in under 4 hours.

2. Risk Solutions

We use a "write once, apply everywhere" approach. A single Risk Solution in our platform maps to multiple requirements.

If you update a control, that change propagates instantly across your entire package. No more "Find and Replace" errors.

3. OSCAL & Human-Readable Compliance Documentation

The RFC requires machine-readable data, but humans (auditors and agencies) still like to read documents. Paramify generates both simultaneously. You get the compliant OSCAL JSON file for the FedRAMP dashboard and a beautifully formatted Word document for your stakeholders.

→ Watch a Video Demo to See Paramify in Action

4. 3PAO Verified

Auditors love accuracy. Major 3PAOs like Schellman have noted that Paramify-generated packages are more accurate and move through the audit process faster than manual ones.

→ See more 3PAO Testimonials ‍or read our G2 Reviews

Frequently Asked Questions

When is the deadline for FedRAMP machine-readable SSPs?

For new authorizations, the deadline is September 30, 2026. For existing authorizations, you must switch to machine-readable packages during your next annual assessment after that date.

What is OSCAL?

OSCAL (Open Security Controls Assessment Language) is a standardized format developed by NIST. It turns static security documents into dynamic, machine-readable code (XML, JSON, YAML).

Does FedRAMP Rev 5 require OSCAL?

Technically, the RFC allows for "approved standardized formats," but explicitly names OSCAL as the primary standard. For all intents and purposes, if you want to be future-proof, you need OSCAL.

How much does an OSCAL SSP cost?

Manual conversion can cost six figures in consulting hours.

Paramify’s automated solution starts around $8,000 - $30,000 per year for low impact data, and $30,000 - $60,000 for moderate/high impact, making it significantly cheaper than the manual alternative.

→ See Paramify Pricing

Next Steps

The FedRAMP RFC-0024 isn't just a suggestion; it is the new roadmap. You can struggle through the transition manually, or you can automate it and be done in a few days.

Don't let the new mandate threaten your certification.

Schedule a Demo with Paramify to see how we can generate your machine-readable, FedRAMP Rev 5 compliant SSP in hours. Have questions? Feel free to reach out anytime, our team loves to chat

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Adam Johnson

A 15 year veteran in software development, product marketing and product management. He's now specializing in Cybersecurity and Compliance.‍ A family man at heart, Adam enjoys biking, soccer, and traveling with his wife and three kids.

Jan 2026

Once authorized, can I sell to any federal agency?

Yes — authorization can be reused by multiple agencies via the FedRAMP Marketplace, but some agencies may request additional requirements.

How is FedRAMP 20x different from traditional FedRAMP?

20x introduces automation, key security indicators (KSIs), continuous monitoring validation, and streamlined authorization (sometimes without sponsor requirements).

→ Compare KSIs to Rev 5 controls

What are the most common reasons for delays or failures in FedRAMP authorization?

Incomplete documentation, insufficient evidence, failing initial gap assessments, lack of executive support, and underestimating resource requirements.

→ How to create the most accurate documentation for audit success

What's the difference between FedRAMP and other frameworks (SOC 2, CMMC, ISO 27001)?

FedRAMP is U.S. government-specific and NIST-based, more prescriptive and granular than commercial standards.

How do inherited controls from my cloud infrastructure provider (e.g., AWS, Azure, GCP) work?

FedRAMP allows CSPs to “inherit” controls from IaaS providers; you must document and verify this inheritance with shared responsibility models.

What kind of technical controls are required under FedRAMP?

Controls follow NIST SP 800-53 Rev 5 (with additional FedRAMP overlays) — covering access control, incident response, risk assessment, configuration management, etc.

→ Get your custom accelerated FedRAMP implementation roadmap

How often do I need to update and submit security documentation?

At minimum:

Monthly POAMs and vulnerability scans
Annual security assessments
Ad hoc submissions for significant changes.

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What is a POA&M?

Plan of Action and Milestones: a document tracking remediation plans for open vulnerabilities, findings, and compliance issues.

→ Learn more about POAMs

What is continuous monitoring (ConMon) and why is it important?

ConMon involves ongoing assessments, vulnerability scanning, reporting POAMs, and keeping security posture current post-authorization.

What documentation is required for FedRAMP?

Major deliverables include a System Security Plan (SSP), Security Assessment Plan (SAP), Security Assessment Report (SAR), Plan of Actions and Milestones (POA&M), Continuous Monitoring (ConMon) documentation, policies/procedures, and more.

Do I need an agency sponsor?

Yes, for now. But, agency sponsorship requirements are evolving — FedRAMP 20x does not require a sponsor.

How do I pick the best 3PAO for my project?

Consider experience with similar environments, references, price, and knowledge of specific cloud implementations.

→ Find the best assessor for your CSP with these tips

What is a 3PAO?

A Third Party Assessment Organization is an accredited independent assessor that conducts key security testing and assessment for FedRAMP.

→ Find a recommended 3PAO

How much does FedRAMP Authorization cost?

Initial costs range from ~$150k to $3M+ for gap assessments, remediation, 3PAO audits, and documentation/reporting.
Annual costs can range from $50k to $1m to maintain documentation, do continuous monitoring, and resource allocation.

→ Learn more about what FedRAMP could cost your organization and whether or not it’s worth the effort

How long does it take to achieve FedRAMP Authorization?

Typical processes take 6–24 months. Paramify accelerates the process to take between 1-10 months with a fully prepared package in less than a month.

Your timeline will vary depending on your impact level, whether you take a manual or automated approach to implementation & documentation, and PMO wait times.

→ Learn about the FedRAMP Authorization process and what it costs.

What’s the difference between FedRAMP Ready, FedRAMP In Process, and FedRAMP Authorized?

Ready: Preliminary review for capability and documentation.
In Process: CSP is actively working toward authorization, usually with an agency sponsor or as part of the JAB program.‍
Authorized: Successfully completed security assessment and continuous monitoring.

What are the different impact levels for FedRAMP?

Low, Moderate, and High — based on the type and sensitivity of federal data hosted (FIPS 199 categories: confidentiality, integrity, availability).

→ Get the details on impact level to know which impact level is right for you.

Do You Need FedRAMP?

Any cloud service provider (CSP) that wants to sell cloud products or services to U.S. federal agencies must be FedRAMP authorized.

→ Learn more to find out if FedRAMP is a good choice for your cloud-based business.

What is FedRAMP

FedRAMP stands for the Federal Risk and Authorization Management Program; it standardizes the security assessment, authorization, and continuous monitoring for cloud products and services used by U.S. federal agencies.

How long will it take to generate my SSP?

If you’re new to FedRAMP: The time required depends on how long it takes to implement your security controls. With Paramify’s living gap assessment dashboard, you can build your compliance roadmap and generate documents instantly with one click.

If you’re already FedRAMP authorized: It can take as little as 3.5 hours or up to a week.

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Can you help me transition from NIST 800-53 Rev 4 to Rev 5?

Yes! No one will help you transition to FedRAMP Rev 5 as affordably and painlessly as Paramify. Learn how you can make a seamless, inexpensive transition to Rev 5.

Can I really generate my SSP in hours?

Are your security controls in place and do you have the certifications and authorizations you need? Then yes, hours it is.

Here’s how one company got their SSP in 3.5 hours.

If you’re in an earlier stage, you may have some security controls in place, but aren’t quite sure which controls need to be satisfied to meet your compliance goals.

Paramify will help you find the gaps in your security program and help you coordinate with your team to address them.

After our intake, you can print your documents at any point. How quickly you can implement your security goals is the only factor in how long it will take you to have a fully accurate and complete SSP.

Do Paramify ATO packages pass audits?

A well-known 3PAO has told us that our customers “are better prepared than other CSPs.”

Our customers have received positive feedback on the accuracy and consistency of their ATO Packages. The Risk Solutions methodology has also been successful at increasing the efficiency and ease of the auditing process.

So yes, the audits are going well.

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Can I use my existing SSP?

Yes, we offer this service and have provided it for many clients. Most of our customers, including those for whom we’ve ingested their SSP, have found that starting from scratch and adopting the full power of Risk Solutions was the better option.

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