What CR26 Means for Your CMMC Audit, and Why FedRAMP Ready Will Matter Less

FedRAMP is expected to finalize its new rulebook on June 30, with mandatory adoption in place by January 2027. Here's what's changing and what to ask your vendors.

If you're a federal contractor running a CMMC Level 2 assessment this year, your security team has probably already asked the question: which of our SaaS tools are FedRAMP authorized, and which ones are claiming something close to it?

It's a fair question, and it's about to get more complicated.

FedRAMP is finalizing Consolidated Rules 2026 (CR26) by June 30, and it's the most significant restructuring the program has had in over a decade. Optional early adoption begins July 1 and mandatory adoption begins January 1, 2027. CR26 changes how authorizations are labeled, how vendors can claim them, and what counts as official marketplace designations versus marketing language. The underlying security requirements don't change much but the labels you've been using to evaluate vendors do, and a few of the labels vendors are leaning on today are going to lose their official standing.

Here's what's coming.

CR26 Explained

CR26 is FedRAMP's replacement for the patchwork of rules, memos, and RFCs that have governed the program since the FedRAMP Authorization Act passed. The PMO is rolling everything into a single consolidated rulebook. CR26 is supported through December 31, 2028, with FedRAMP planning annual updates (CR27, CR28) along the way for ongoing maintenance.

The intent is to give the community a stable rulebook to work against for the next couple of years, with predictable annual maintenance instead of the rolling RFC churn we've all been navigating.

CR26 timeline at a glance:

• June 30, 2026: CR26 finalized
• July 1, 2026: Optional early adoption begins
• July 28, 2026: "FedRAMP Ready" designation retires; renamed "Legacy FedRAMP Ready"; no new submissions accepted
• November 17, 2026: Legacy Ready listings begin expiring (or at their assessment expiration, whichever is later)
• January 1, 2027: Mandatory CR26 adoption begins
• December 31, 2028: CR26 sunsets and is replaced by the next Consolidated Rules

A few things in CR26 are worth understanding before you start evaluating vendors against the new framework.

A new name for the designation

The single label across all FedRAMP paths going forward is "FedRAMP Certification" or "FedRAMP Certified." "FedRAMP Authorized," the term you've been seeing on vendor websites for years, is being retired as the operative phrase. A vendor that is FedRAMP Authorized today becomes FedRAMP Certified under CR26. Same controls, same boundary, new label.

The change is mostly cosmetic, but if your team relies on contract language or SSP templates that hard-code "FedRAMP Authorized," it's worth a pass through your boilerplate before the change takes effect.

Letter classes replace Low, Moderate, and High

FedRAMP is also replacing the FIPS 199 impact level labels with letter classes:

• Class A: entry-level designation, intended as a step toward Class B, C, or D after agency adoption
• Class B: maps to Low and Li-SaaS
• Class C: maps to Moderate
• Class D: maps to High

The reason is practical. FedRAMP's Low, Moderate, and High designations kept getting confused with DoD Impact Levels, which use similar terminology but mean different things. The letter classes eliminate that overlap.

Class A deserves a quick note, because it's the closest thing to a successor for FedRAMP Ready, but it isn't a one-to-one rename. FedRAMP describes Class A as an entry-level designation for cloud services with mature security and compliance programs that are entering the federal marketplace, with the expectation that they'll transition to Class B, C, or D after agency adoption. If a vendor is in Ready today, Class A is the successor path, but it's a new designation with its own requirements, not an automatic conversion.

For most DoD CUI/CDI workflows, Class C, formerly Moderate, is the level customers and assessors will expect to see. That's where the majority of the FedRAMP Marketplace lives, and where most federal SaaS tools targeting defense and CUI-adjacent contracts aim. Class B may be appropriate for non-CUI federal workloads. If you're handling CUI under DoD contracts, Class C is what you should be looking for.

FedRAMP Ready Retires on July 28

This is the one to watch.

"FedRAMP Ready" has been a marketplace designation for years. It means a 3PAO has done a Readiness Assessment and confirmed the vendor could likely become fully authorized if they had an agency sponsor. FedRAMP Ready is not an authorization. It's a readiness designation, and it should not be treated as equivalent to FedRAMP Authorized or FedRAMP Certified status. A Ready listing tells you a vendor is technically prepared for assessment, not that they have one.

CR26 retires the Ready designation on July 28, 2026. Existing Ready listings get renamed "Legacy FedRAMP Ready" and expire by November 17, 2026,or at their assessment expiration. New submissions won't be accepted after July 28, 2026 and Legacy Ready offerings won't be eligible for FedRAMP Certification under the new model. These vendors will need to start fresh on a Certification track. Vendors currently in Ready limbo need an actual plan to convert before July 28, or they will end up holding a status that's about to be deprecated.

If you're evaluating a vendor that has recently announced "FedRAMP Ready" status, it's worth asking them what the August path looks like. Do they have a sponsor lined up? Are they pursuing Class A under CR26, or the limited Rev5 Certification-without-sponsor path FedRAMP is offering during the transition? "We're FedRAMP Ready" means something different in May than it does in August.

Moderate Equivalency Doesn't Translate

The last piece is the most direct. The FedRAMP PMO stated explicitly at their April 1, 2026 community meeting that FedRAMP does not have a concept of "Moderate Equivalency." It's a DoD/DISA construct from a December 2023 memo. FedRAMP will not make commitments based on it, and providers holding Moderate Equivalency should not expect any head start or crossover value toward any FedRAMP Certification class.

If you're evaluating a vendor that leans on Moderate Equivalency it isn't a substitute for FedRAMP Authorization if your contract or your customers require official standing.

How to Act in the Next 90 days

If you have FedRAMP-relevant SaaS in your stack, here’s what you can do to prepare before the new framework lands.

Start by auditing your stack against the new labels. For each FedRAMP-relevant tool in your environment, write down what they claim today and what they'll be under CR26. Most of the time the conversion is clean. Authorized becomes Certified, Moderate becomes Class C, and you're squared away. The places to focus are situations where vendors are claiming Ready or Equivalency. Those don't have a clean conversion path, and the operational status of those vendors will look different on August 1 than it does today.

While you're at it, update your SSP templates. Boilerplate templates that hard-code "FedRAMP Authorized" or "FedRAMP Moderate" should accommodate the new language. Most auditors will understand the transition, but giving them a document that uses current terminology saves you a back-and-forth.

Additionally, be sure to ask your vendors a direct question: which Class will you be in under CR26? It's a fast way to surface vendors who haven't thought about the transition. A vendor that's FedRAMP Authorized today should be able to answer immediately: Class C. A vendor that's Ready or Equivalent should be able to tell you what they're pursuing instead, and on what timeline.

What This Means for Procurement Sciences Customers

For Awarded AI users, the practical impact is straightforward: CR26 does not create a reauthorization event for Procurement Sciences

Procurement Sciences achieved FedRAMP Moderate Authorization on March 13, 2026, hosted in a FedRAMP-authorized environment. Under CR26, it becomes FedRAMP Certified at Class C. It doesn't need to re-authorize, there's no transition risk, and there's nothing for your team to redo. Procurement Sciences’ marketplace listing stays valid, the controls our customers rely on stay in place, and the work your security team has already done to document us in your SSP holds up.

We pursued full Authorization because we wanted our customers to get meaningful security for their pursuits.

The most important factor is speed to value. If you sign with us, you can put Awarded AI on federal work right away, without stalling on whether the security side will hold up under a CMMC assessment or a customer security review. Closely related is speed on security review. When your security team or your assessor digs into the package, the work is already done and independently validated, on the public Marketplace, available to any agency that wants it. Underneath both of those, the actual point: your CUI lives where it's supposed to live, under controls that have been independently tested, in an environment with continuous monitoring obligations to FedRAMP itself.

Compliance done well shouldn't slow your business down. It should make security reviews faster, procurement cycles shorter, and give your customers something defensible to point at when an assessor asks the hard question. CR26 doesn't change any of that. It just standardizes the vocabulary everyone uses to describe it.

Connect With Our Security Experts 

We hold office hours for customers and prospects working through CMMC documentation. If you want to sanity-check how your SaaS stack lines up against the new CR26 landscape, or how to write up Procurement Sciences in your SSP, book time with our security team or email us at compliance@procurementsciences.com.

Stay tuned for more information on CR26. We’ll cover how to read a FedRAMP Marketplace listing in 30 seconds and what each line tells your auditor.

John Bullough is Chief Information Security Officer at Procurement Sciences, where he leads security, IT, and platform for the company's AI growth platform purpose-built for government contractors. Procurement Sciences achieved FedRAMP Moderate Authorization in March 2026.