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FedRAMP RFC and policy tracker

FedRAMP RFC and Policy Tracker

Key takeaway: As of October 14, 2026, fedramp.gov lists 35 Requests for Comment (RFCs) and 16 public notices. One RFC is open: RFC-0035, Cryptographic Module Use Rules Updates, with comments due November 17, 2026. The next hard date for providers is December 7, 2026, when the Vulnerability Detection and Response (VDR) and Vulnerability Evaluation and Reporting (VER) rules take effect under Notice NTC-0014. There is no September 2026 OSCAL deadline: RFC-0024 proposed one, and Notice NTC-0009 and Consolidated Rules 2026 (CR26) replaced it.


This tracker follows each RFC from proposal to notice to rule and shows the dates a provider has to plan against. It is built from the fedramp.gov RFC and notice indexes and carries the date it was last checked.

35RFCs on fedramp.gov: 1 open, 34 closed
16public notices, NTC-0001 through NTC-0016
Nov 17, 2026RFC-0035 comments due
Dec 7, 2026VDR and VER take effect

Dates checked against fedramp.gov on October 14, 2026. fedramp.gov is the authoritative source.

Open now

What is open for comment, and what is waiting on an outcome

One RFC is open on fedramp.gov. Three recent RFCs have closed and are waiting on an outcome notice.

Open until November 17, 2026

RFC-0035: Cryptographic Module Use Rules Updates

Defines a CMVP-Validated Module as a cryptographic module with an active validation in the NIST Cryptographic Module Validation Program, or an update stream of one.
Changes CMU-CSO-UVM for Class D from MUST to SHOULD, matching Class C.
Adds CMU-CSO-TSC, which treats replacing a CMVP-validated module with a non-validated one as a transformative change for Class B, C and D.
Moves the update-stream note into the new definition.
Who it touches

Rev5 and 20x providers under CR26

The RFC applies to CR26 for both Rev5 and 20x.
Under CMU-CSO-UVM, Class A and B providers MAY use CMVP-validated modules and Class C and D providers SHOULD.
FedRAMP states that currently operating cloud services do not need to change anything.
The RFC does not change agency obligations under FIPS 140-3 and does not set post-quantum cryptography requirements.

Closed, awaiting an outcome

Three RFCs have closed without a posted outcome. FedRAMP announces outcomes in a notice.

Closed Oct 9, 2026

RFC-0033: 20x Phase 4 for Class D

Proposed three tracks: a Class D cloud-hosted pilot limited to 10 participants, a track for self-hosted and hybrid-hosted services, and a track for independent assessment services. As proposed, pilot applicants needed a CR26-compliant 20x Class C Certification before December 1, 2026. No outcome is posted yet.

Closed Oct 9, 2026

RFC-0034: Technical Advisory Group

Proposes a Technical Advisory Group of agency security staff on details of up to six months at FedRAMP, with an initial cohort of up to 10 members and a cohort opening planned for October 2026. No outcome is posted yet.

Closed Sep 8, 2026

RFC-0032: Offerings By Government

Proposes a certification pathway for cloud services that federal agencies operate for other agencies, mapped from the operating agency's ATO impact level: Low to Class B, Moderate to Class C and High to Class D. No outcome is posted yet.

RFC-0033 scheduled a full Class D pilot requirements RFC for October 14, 2026. It was not on the RFC index when this page was checked. FedRAMP has said 20x Class D Program Certification is coming in 2027, and Rev5 Class D requires Agency Certification.

Primary sources FedRAMP RFC index, RFC-0035, RFC-0033, RFC-0034, RFC-0032.

Dates

Dates providers plan against

These dates come from the notices that announced RFC outcomes and from the CR26 deadlines page. They are fixed rules, not forecasts.

Dates that follow from FedRAMP RFC outcomes, what takes effect, who it applies to, and status
DateWhat takes effectWho it applies toStatus
Jul 4, 202620x rules in effect: incident evaluation and response (NTC-0012), Certification Data Sharing and Significant Change Notification to obtain certification.Providers seeking a 20x Certification.In effect
Dec 7, 2026VDR and VER become mandatory (NTC-0014). Legacy monthly vulnerability scanning is no longer enough.Every offering obtaining or maintaining FedRAMP Certification, Rev5 and 20x.Next
Jan 1, 2027CR26 applies to every new Rev5 application, and to existing Rev5 offerings at the first independent assessment completed after this date (NTC-0013). Updated incident rules apply to Rev5 and to pilot 20x maintenance (NTC-0012). The Significant Change Notification ruleset applies to Rev5.Rev5 providers, and pilot 20x providers maintaining certification.Planned
Mar 7, 2027The VDR and VER grace period ends. Offerings that are not following the rules lose certification (NTC-0014).Offerings on a corrective action plan.Planned
Apr 2, 2027Collaborative Continuous Monitoring to maintain certification, Rev5 (grace period to October 1, 2027).Rev5 providers.Planned
Jun 11, 2027FedRAMP stops accepting new Rev5 Certification requests (NTC-0013). Significant Change Notification grace period ends June 1, 2027.Providers planning a new Rev5 application.Planned
Aug 1, 2027Certification Data Sharing to maintain certification, Rev5 (grace period to February 1, 2028).Rev5 providers.Planned

For existing Rev5 certifications, NTC-0013 says no end date is final and that it is likely no later than 2029. NTC-0009 listed anticipated dates before CR26 was final. Where they differ, the CR26 deadlines page governs.

No September 2026 OSCAL date

What happened to the September 2026 date

RFC-0024, issued January 13, 2026, proposed machine-readable packages for Rev5 providers with a September 2026 date. FedRAMP published the initial outcome in Notice NTC-0009 on March 25, 2026 and the final rules in CR26 on June 24, 2026. The CR26 schedule replaced the September date. Machine-readable data now sits under Certification Data Sharing, covered on the OSCAL page.

Primary sources CR26 important dates, CR26 Rev5 deadlines, Notice NTC-0014, Notice NTC-0013, Notice NTC-0012, Notice NTC-0009.

From RFC to rule

How an RFC becomes a rule

RFC opens

FedRAMP posts a proposed rule or standard for public comment, with a comment period.

Comments close

The RFC moves to the closed list. Closed RFCs show their closing date.

Notice with the initial outcome

FedRAMP posts a notice that says what changed and often gives the dates, as with NTC-0009, NTC-0012 and NTC-0013.

Rule in the Consolidated Rules

The final rule and its dates land in CR26, with separate dates for Rev5 and 20x.

Not every RFC ends in a rule. RFC-0019 was not finalized, RFC-0008 was superseded by RFC-0012 and RFC-0003 was entirely rescinded. A date in an RFC is a proposal until a notice or CR26 repeats it, which is how the September 2026 date from RFC-0024 fell away.

RFC register

Every FedRAMP RFC, and how it ended

35 RFCs, newest first. Outcomes are as fedramp.gov lists them.

2026: RFC-0019 through RFC-0035

Every RFC on fedramp.gov from the January 2026 release to today.

RFCs posted in 2026, with title, status and outcome
RFCTitleStatusOutcome
RFC-0035Cryptographic Module Use Rules UpdatesOpen until Nov 17, 2026Opened October 14, 2026. Proposes a CMVP-Validated Module definition and changes to the cryptographic module use rules for CR26.
RFC-0034Technical Advisory Group ChangesClosed Oct 9, 2026No outcome posted yet.
RFC-003320x Phase 4 Development Tracks for 20x Class DClosed Oct 9, 2026No outcome posted yet. Proposes a Class D pilot and tracks for self-hosted services.
RFC-0032Offerings By GovernmentClosed Sep 8, 2026No outcome posted yet.
RFC-0031Updated Incident Communications ProceduresClosed May 12, 2026Initial outcome in NTC-0012 (June 3, 2026). Effective July 4, 2026 for 20x and January 1, 2027 for Rev5.
RFC-0030Rev5 Security Controls Baseline Update for RA, SA, SC, SI and SRClosed Apr 22, 2026Initial outcome in NTC-0013 (June 16, 2026).
RFC-0029Rev5 Security Controls Baseline Update for PE, PL, PM, PS and PTClosed Apr 22, 2026Initial outcome in NTC-0013 (June 16, 2026).
RFC-0028Rev5 Security Controls Baseline Update for CP, IA, IR, MA and MPClosed Apr 22, 2026Initial outcome in NTC-0013 (June 16, 2026).
RFC-0027Rev5 Security Controls Baseline Update for AC, AT, AU, CA and CMClosed Apr 22, 2026Initial outcome in NTC-0013 (June 16, 2026).
RFC-0026Clarifying CA-7 Continuous Monitoring Expectations for Rev5 ProvidersClosed Apr 22, 2026Initial outcome in NTC-0013 (June 16, 2026).
RFC-0025Retrospective on the Public Comment ProcessClosed Apr 21, 2026Initial outcome in NTC-0011 (May 27, 2026).
RFC-0024Rev5 Machine-Readable PackagesClosed Mar 11, 2026Initial outcome in NTC-0009 (March 25, 2026), final rules in CR26. The proposed September 2026 date was replaced.
RFC-0023Rev5 Program Certifications (No Sponsor Required)Closed Feb 26, 2026Initial outcome in NTC-0008 (March 6, 2026).
RFC-0022Leveraging External FrameworksClosed Feb 26, 2026Initial outcome in NTC-0007 (March 3, 2026).
RFC-0021Expanding the FedRAMP MarketplaceClosed Feb 19, 2026Initial outcome in NTC-0005 (February 25, 2026).
RFC-0020FedRAMP Authorization DesignationsClosed Feb 19, 2026Initial outcome in NTC-0004 (February 25, 2026).
RFC-0019Reporting Assessment CostsClosed Feb 12, 2026Not finalized or implemented. Outcome in NTC-0002 (February 18, 2026).

2025: RFC-0001 through RFC-0018

The RFCs that shaped 20x, Key Security Indicators and the Balance Improvement Releases.

RFCs closed in 2025, with title, status and outcome
RFCTitleStatusOutcome
RFC-0018FedRAMP Security Inbox RequirementsClosed Nov 17, 2025Reworked to cover FedRAMP communications. Applies to 20x and Rev5.
RFC-0017Persistent Validation and Assessment StandardClosed Nov 17, 2025Published as the Persistent Validation and Assessment standard for 20x.
RFC-0016Collaborative Continuous MonitoringClosed Nov 17, 2025Published as the Collaborative Continuous Monitoring standard for 20x.
RFC-0015Recommended Secure Configuration StandardClosed Nov 17, 2025Published as Recommended Secure Configuration guidance.
RFC-0014Phase Two Key Security IndicatorsClosed Nov 17, 2025Documented in the Phase Two Key Security Indicators standard.
RFC-0013SC-7 Boundary Protection Balance Improvement ReleaseClosed Sep 11, 2025Wording tweaked. All FedRAMP Rev5 baselines updated.
RFC-0012Continuous Vulnerability Management StandardClosed Aug 21, 2025Released as the Vulnerability Detection and Response requirements.
RFC-0011Pilot Standard for Storing and Sharing Authorization DataClosed Jun 22, 2025Released as the Authorization Data Sharing standard.
RFC-0010Scope Interpretation Technical AssistanceClosed Jun 15, 2025Posted publicly as the Scope of FedRAMP.
RFC-0009Significant Change Notification Technical AssistanceClosed Jun 15, 2025Integrated into the Significant Change Notification requirements.
RFC-0008Continuous Reporting StandardClosed Jun 9, 2025Did not move forward. Superseded by RFC-0012.
RFC-0007Significant Change Notification StandardClosed May 25, 2025Finalized with considerable changes. Applied to 20x.
RFC-000620x Phase One Key Security IndicatorsClosed May 25, 2025Finalized and published.
RFC-0005Minimum Assessment ScopeClosed May 25, 2025Formalized as a 20x standard, with partial Rev5 support later.
RFC-0004Boundary PolicyClosed Apr 2, 2025Replaced by the follow-up RFC-0005, Minimum Assessment Scope.
RFC-0003Review Initiation Checks (RICs)Closed Apr 2, 2025Entirely rescinded.
RFC-0002Proposed Revisions to FedRAMP 3PAO RequirementsClosed Apr 2, 2025Sent to A2LA with modifications.
RFC-0001A New Comment Process for FedRAMPClosed Apr 2, 2025The RFC process continues, with periodic review.

Primary sources FedRAMP RFC index.

Public notices

FedRAMP notices since February 2026

FedRAMP began publishing numbered public notices on February 18, 2026.

FedRAMP public notices, with date posted and title
NoticePostedTitle
NTC-0016Jul 22, 2026Outcome from the FY26 Q4 FedRAMP Security Inbox Test
NTC-0015Jul 7, 2026Emergency Test: FY26 Q4 FedRAMP Security Inbox Test
NTC-0014Jun 16, 2026FedRAMP Response to CISA BOD 26-04 (Prioritizing Security Updates Based on Risk). VDR and VER mandatory December 7, 2026.
NTC-0013Jun 16, 2026Initial Outcome of Rev5 Baseline RFCs (RFC-0026 through RFC-0030)
NTC-0012Jun 3, 2026Initial Outcome of RFC-0031, Updated Incident Communications Procedures
NTC-0011May 27, 2026Initial Outcome of RFC-0025, Retrospective on the Public Comment Process
NTC-0010Apr 23, 2026FedRAMP Response to CISA ED 25-03
NTC-0009Mar 25, 2026Initial Outcome of RFC-0024, Rev5 Machine-Readable Packages
NTC-0008Mar 6, 2026Initial Outcome of RFC-0023, Rev5 Program Certifications
NTC-0007Mar 3, 2026Initial Outcome of RFC-0022, Leveraging External Frameworks
NTC-0006Feb 25, 2026Emergency Directive 26-03, Mitigate Vulnerabilities in SD-WAN Systems
NTC-0005Feb 25, 2026Initial Outcome of RFC-0021, Expanding the FedRAMP Marketplace
NTC-0004Feb 25, 2026Initial Outcome of RFC-0020, FedRAMP Authorization Designations
NTC-0003Feb 18, 2026Notification of Planned FY26 Q2 FedRAMP Security Inbox Test
NTC-0002Feb 18, 2026Outcome from RFC-0019, Reporting Assessment Costs
NTC-0001Feb 18, 2026Introducing FedRAMP Public Notices

fedramp.gov numbers its notices 0001 through 0016, and its RFC pages refer to them as NTC. Notices announce RFC outcomes, respond to federal directives such as CISA BOD 26-04, and report operational events such as the quarterly security inbox test.

Primary sources FedRAMP notice index.

What to do now

Four decisions on the calendar

Quzara does not promise authorization timelines. These are the dates FedRAMP has published.

Before December 7, 2026

Move vulnerability management to the VDR and VER rules. Plan for evaluating internet reachability, exploitability and KEV status, not monthly scans alone. The grace period to March 7, 2027 runs under a corrective action plan.

Before November 17, 2026

If you run cryptographic modules, read RFC-0035 and comment. FedRAMP states that currently operating services do not need to change anything.

Rev5 providers

Plan the move to CR26 for your next independent assessment after January 1, 2027, and decide before June 11, 2027 whether a new Rev5 application is still your path.

Class D and 20x

Watch the RFC-0033 outcome. It proposed a Class D pilot and requires a CR26-compliant 20x Class C Certification first. Treat it as a proposal until FedRAMP posts the outcome.

Quzara

Turn each rule change into evidence, not a rewrite

Cybertorch produces the operating evidence. NISTcompliance.ai structures it into the package the rules require.

Vulnerability data for VDR and VER

Cybertorch is a 24/7 U.S. citizen SOC on Azure Government, FedRAMP Certified Class D (High), with vulnerability management that supplies evidence for the rules effective December 7, 2026.

Packages that follow the rules

NISTcompliance.ai generates SSP and POA&M drafts and OSCAL from control evidence, so a rule change becomes an update to the record instead of a rewrite.

Gap analysis across frameworks

Control mapping across NIST SP 800-53 Rev 5, FedRAMP, FISMA and CMMC Level 2, so each change is checked against every framework you carry.

Advisory

FedRAMP advisory, ISSO support and continuous monitoring from Quzara, available through our GSA HACS vehicle.

NISTcompliance.ai operates inside the Cybertorch FedRAMP boundary on Azure Government. AI drafts and compares, and ISSOs, assessors and authorizing officials make every determination.

Common questions about FedRAMP RFCs and notices

What is a FedRAMP RFC?
A Request for Comment is FedRAMP's public process for proposing a rule or standard before it takes effect. fedramp.gov lists open and closed RFCs with their outcomes.
Which RFC is open now?
As of October 14, 2026, RFC-0035, Cryptographic Module Use Rules Updates, which opened October 14, 2026 and closes November 17, 2026.
How does an RFC become a rule?
After comments close, FedRAMP posts a notice with the initial outcome, and the final rule and its dates appear in the Consolidated Rules for 2026 (CR26). Some RFCs end without a rule: RFC-0019 was not finalized, RFC-0008 was superseded and RFC-0003 was rescinded.
What is the difference between an RFC and a notice?
An RFC proposes a rule and collects comments. A notice announces an outcome, responds to a federal directive or reports an operational event, such as the quarterly security inbox test.
Is there a September 2026 OSCAL deadline?
No. RFC-0024 proposed one for Rev5 providers on January 13, 2026. The outcome in Notice NTC-0009 and in CR26 replaced it. Machine-readable data now follows the Certification Data Sharing dates: January 1, 2027 to obtain and August 1, 2027 to maintain for Rev5.
What is the next deadline I must plan against?
December 7, 2026, when VDR and VER become mandatory for every offering obtaining or maintaining FedRAMP Certification. The grace period ends March 7, 2027, after which certification is revoked for offerings that do not follow the rules (NTC-0014).
What did RFC-0033 propose?
A Phase 4 pilot for 20x Class D: a cloud-hosted track limited to 10 participants, plus tracks for self-hosted and hybrid-hosted services and for independent assessment services. The RFC closed October 9, 2026 and no outcome is posted yet. FedRAMP has said 20x Class D Program Certification is coming in 2027.
Does RFC-0035 change what a current provider must do?
FedRAMP states that currently operating cloud services do not need to change anything. The RFC proposes changing CMU-CSO-UVM for Class D from MUST to SHOULD and adding CMU-CSO-TSC, which treats replacing a CMVP-validated module with a non-validated one as a transformative change.
Where do the final rules live?
In the Consolidated Rules for 2026 at fedramp.gov/2026, which apply to both 20x and Rev5 with separate dates. The Important Dates page on the same site tracks the milestones.
How current is this tracker?
It states the date it was last checked against fedramp.gov, at the top of the page. fedramp.gov is the authoritative source, so confirm a date there before you rely on it.
How does Quzara help with a rule change?
Cybertorch supplies the operating evidence, including vulnerability data, and NISTcompliance.ai turns it into SSP and POA&M drafts and OSCAL inside the same FedRAMP boundary. Quzara advisory maps each change to your package.

Plan your roadmap against the FedRAMP rule changes

Quzara advisory, Cybertorch monitoring and NISTcompliance.ai automation help you meet each date with evidence. Engage Quzara through our GSA HACS vehicle or directly.