FedRAMP Penetration Testing Requirements
FedRAMP (the Federal Risk and Authorization Management Program) is the US government programme that standardizes security for cloud services used by federal agencies. Every cloud service offering pursuing or holding an Authorization to Operate must undergo annual penetration testing.
This guide breaks down what FedRAMP requires for penetration testing, the mandatory attack vectors your test must cover, the role of the 3PAO, and how the requirement ties back to NIST control CA-8.
What FedRAMP Requires for Penetration Testing
FedRAMP builds on the NIST SP 800-53 baseline and adds cloud-specific testing rules through the FedRAMP Penetration Test Guidance. The obligations that shape your engagement are:
Annual Testing (CA-8)
A penetration test at least once a year for every cloud service offering seeking or maintaining an Authorization to Operate
Mandatory Attack Vectors
Defined vectors every test must cover: external, internal, web and API, social engineering, and cloud tenant and management boundaries
3PAO Assessment
A FedRAMP-accredited Third Party Assessment Organization performs or validates the formal annual test
Continuous Monitoring
Test results feed the continuous monitoring programme that maintains the system's authorization over time
Assessors expect documented coverage of every mandated attack vector, with findings mapped to the system boundary described in your System Security Plan.
The FedRAMP Mandatory Attack Vectors
The FedRAMP Penetration Test Guidance is prescriptive about what a test must cover. The core vectors are:
External and Internal Network Testing
Testers assess the system from an external attacker's position and from inside the boundary, simulating both an outside adversary and a compromised internal host attempting lateral movement.
Web Application and API Testing
Every internet-facing application and API in the boundary is tested for the OWASP class of vulnerabilities, authentication and authorization flaws, and business-logic weaknesses.
Social Engineering and Tenant Boundaries
The guidance requires social engineering (such as phishing) and testing of the separation between tenants and between the management plane and customer environments, which is critical for multi-tenant cloud services.
FedRAMP Scope and Authorization
Who is in scope
Cloud service providers offering services to US federal agencies, at Low, Moderate, or High impact levels under the FedRAMP baseline.
The system boundary
Testing covers the authorization boundary defined in the System Security Plan, including all in-scope applications, APIs, and infrastructure.
Annual cadence
A full penetration test at least once a year, plus testing after significant changes, to sustain the Authorization to Operate.
Evidence for the ATO
Results are packaged for the 3PAO assessment and the agency authorizing official as part of the continuous monitoring deliverables.
How Budget Security Helps You Meet FedRAMP
Budget Security delivers penetration testing that covers the FedRAMP mandatory attack vectors and follows the NIST SP 800-115 methodology. Use our platform to scope and launch engagements ahead of your 3PAO assessment, starting at EUR 849 per day.
Scope to your authorization boundary
Define the cloud applications, APIs, and infrastructure inside your System Security Plan so testing matches exactly what the 3PAO will assess.
Full attack-vector coverage
Our engagements are structured to document each FedRAMP mandated vector, from external and internal network testing to tenant-boundary and social engineering.
Assessment-ready reporting
Reports map findings to NIST controls with CVSS v3.1 scores and exploitation evidence, formatted to slot into your 3PAO and continuous monitoring package.
Remediation tracking and retesting
Fix issues ahead of the formal assessment using our vulnerability dashboard, then retest to confirm remediation before the 3PAO reviews.
Get Your FedRAMP Pentest Quote
See exactly what your FedRAMP-aligned penetration test would cost. Engagements cover the mandatory attack vectors and map findings to NIST controls, ready for your 3PAO assessment.