When it comes to managing FedRAMP-compliant systems, it helps to understand the entirety of the system that will fall under this jurisdiction. Unfortunately, with the complexity of cloud systems being what they are, mapping out IT systems with the right granularity can provide a challenge. This is why FedRAMP guides determining an organization’s authorization boundary.
How Does the FedRAMP Program Define an Authorization Boundary?
Cloud service providers preparing to run their offerings through the FedRAMP process must first determine the authorization boundary of their system. This boundary will include all the platforms, software, hardware, security components, and other infrastructure within which federal data and metadata will be stored, transmitted, or processed.
The CIO Council’s Circular OMB A-130 states that an authorization boundary should inventory a cloud system’s internal components and external connections–both of which present unique challenges and requirements to the CSP.
Federal Data in Your Cloud Infrastructure
OMB A-130 defines federal information as “information created, collected, processed, maintained, disseminated, disclosed, or disposed of by or for the Federal Government.”
With this relatively specific definition in place, it follows that any component of a cloud infrastructure containing this data would fall under FedRAMP and thus be part of the authorization boundary.
Federal Metadata in Your Cloud Infrastructure
In common parlance, metadata is literally “data about data” or data that describes functions or features of other information. According to NIST SP 800-53, metadata may include descriptions of data architecture, formats, contents, or security labels.
Under FedRAMP authorization boundary guidelines, metadata will fall under two different classifications:
- Data that describes information about a federal customer and their activities on a cloud offering, including activity logs and scripts, or
- Information that impacts the confidentiality, integrity, and availability (CIA) of that federal customer’s information and the system it is contained in. This information can include audit logs, scripts, or vulnerability reports.
Cloud systems must be secured if they handle federal metadata, just as they would if they managed traditional data. Providers must account for those handling federal metadata in FedRAMP inventories to determine the CSP’s authorization boundary.
Cloud Interconnections
NIST SP 800-47 defines interconnections as the direct connection between two more IT systems to share data and resources. The “interconnection” is the mechanism that connects two systems and can be represented as an integrated software service, an API service, an Ethernet or fiber optic connection, or any combination of hardware and services. These interconnections can provide data streams for automated IT systems, online and always-on communications, online training, and data backup.
External Cloud Services
According to NIST 800-53, external services are systems that are used by, but are not part of, an organization system. These systems are under partial or complete control of a third-party vendor, and there are typically trusted relationships between authorized parties across the primary organization and the vendor.
Because modern technology relies so heavily on augmenting technical capabilities through cloud platforms and managed services, it isn’t realistic to think that every CSP’s offering is 100% contained on-premise. However, because the third-party system essentially extends the authorization boundary, that vendor (and their offering) must meet minimum FedRAMP requirements (and have authorization) commensurate with the data they process for their client.
How To Determine Your FedRAMP Authorization Boundary
With these criteria and definitions in place, it’s somewhat straightforward to determine your authorization boundary. This process will include tallying the systems that touch sensitive FedRAMP information.
The simple rules that FedRAMP puts forth to help organizations include the following:
- Internal Services Processing Federal Data: organizations should conduct due diligence in order to determine their internal IT systems and how they interact with regulated federal data. There should be a clear delineation between the inside and outside of that system when it comes to internal services (on-premise systems, applications, cloud infrastructure, etc.). That is, systems governed 100% by your organization, those not governed by your organization, and systems that aren’t interacting with federal data.
- External Services Impacting Federal Data: If you work with an external service provider that contains federal data or provides services that impact the CIA of data or metadata, these external services must be considered inside your authority boundary. Providers must report these services to their Authorization Officer. If they don’t have their own standing FedRAMP ATO, they must provide a scope of assessment to provide your AO with the information they need for appropriate risk management.
- Corporate Services: Corporate services support daily business operations and stand somewhat outside the scope of mission-critical IT infrastructure. These can include ticketing and customer service operations, billing, marketing, etc. So long as these services do not impact the CIA or federal information, they can be considered outside your authorization boundary. However, ensuring that these services don’t potentially open security vulnerabilities through unintended interactions (like an accidental release of vulnerability information via insecure channels) is critical.
- Development Environments: A development environment mirroring an existing IT system or software products for customers may be considered outside the authorization boundary so long as it does not contain federal data or metadata. The AO must review these environments to see if any interconnections exist between them and regulated systems.
With all of these different instances of what sits inside and outside an authorization boundary, FedRAMP recommends that organizations have a network diagram highlighting all the systems that make up that boundary. This Authorization Boundary Diagram (ABD) helps JAB and assessment organizations not only understand the components that make up that boundary but also how to assess risk management issues related to the interconnections of boundary systems and the relationships between CSPs and third-party managed service providers.
Is Your Cloud Infrastructure Ready for FedRAMP Authorization?
Platforms, software, user interfaces, third-party vendors–each component of a cloud system can potentially impact FedRAMP compliance. It takes serious attention to detail regarding inventories, component interactions, and proper security protocols to ensure that every device and module within your FedRAMP boundary is adequately protected.
What Is Autonomous Malware?
We’re reaching the end of 2025, and looking ahead to 2026, most experts are discussing the latest threats that will shape the year ahead. This year, we’re seeing a new, but not unexpected, shift to autonomous threats driven by state-sponsored actors and AI. With that in mind, a new generation of threats, broadly known as...Continue reading→
What CISA’s Emergency Directive 26-01 Means for Everyone
In mid-October 2025, the CISA issued one of its most urgent orders yet: Emergency Directive 26-01. The directive calls on all Federal Civilian Executive Branch (FCEB) agencies to immediately mitigate vulnerabilities in devices from F5 Networks following a state-sponsored breach of F5’s systems and access to portions of BIG-IP source code and vulnerability data. The event...Continue reading→
Cybersecurity and Vetting AI-Powered Tools
A recent exploit involving a new AI-focused browser shone a light on a critical problem–namely, that browser security is a constant issue, and AI is just making that threat more pronounced. Attackers discovered a way to use that browser’s memory features to implant hidden instructions inside an AI assistant. Once stored, those instructions triggered unwanted...Continue reading→
Shutdown Security And Cyber Vulnerability
When the federal government shuts down, the public sees closed monuments, unpaid workers, and halted programs. What they do not see is the silent surge of cyberattacks targeting agencies already operating on fumes. During the most recent shutdown, attacks against U.S. government systems spiked by nearly 85%. Cybersecurity failures during government disruptions rarely start with...Continue reading→
Identity and the Shift from Malware
The world of cyber threats is rapidly evolving, and while we can see these changes more generally, it’s always crucial to understand them concretely. As the 2025 CrowdStrike Global Threat Report shows us, the landscape of our industry is changing. We’re digging into this report to discuss a challenging trend: the move of hackers foregoing...Continue reading→
Maintaining Compliance Against Prompt Injection Attacks
The increasing adoption of AI by businesses introduces security risks that current cybersecurity frameworks are not prepared to address. A particularly complex emerging threat is prompt injection attacks. These attacks manipulate the integrity of large language models and other AI systems, potentially compromising security protocols and legal compliance. Organizations adopting AI must have a plan...Continue reading→
Are We Already Talking About CMMC 3.0?
The ink has barely dried on the CMMC final rule, and already the defense contracting community is buzzing with speculation about what comes next. Just when contractors thought they had a moment to catch their breath after years of regulatory limbo, whispers of CMMC 3.0 have begun circulating through the industry. But is this just...Continue reading→
Centralizing Identity-Based Risk
As the traditional network boundary dissolves and remote work becomes standard practice, identities are the major frontier for security. Whether we’re talking about human users, service accounts, or machine identities, these have emerged as both the primary access mechanism and the most targeted attack vector. It has become imperative for providers to centralize identity management...Continue reading→
Deviation and Significant Change Requests in FedRAMP: A Comprehensive Guide
FedRAMP provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by federal agencies. While the program’s rigorous baseline requirements ensure consistent security, the reality is that this consistency calls for a little flexibility. This is where deviation requests and significant change requests come into play. These two...Continue reading→
The Costs of Compliance and Data Breaches
Data is possibly one of the most valuable assets any organization holds. Customer information, employee records, and proprietary business intelligence present challenges because the data flowing through modern enterprises represents both significant opportunities and serious risks. Businesses face a challenging balance: investing in compliance measures to protect sensitive information while also preparing for the real...Continue reading→
Related Posts