FedRAMP High — 421 Controls

Inherit More Controls.
Accelerate Your ATO.

Every control you inherit from SecureWatch's FedRAMP High authorization is one fewer control your team must independently implement, document, and assess. Our Customer Responsibility Matrix maps exactly what you inherit — and our AI keeps proving it in real time.

What Is a Customer Responsibility Matrix?

When you deploy on a FedRAMP-authorized platform, you don't start from zero. The cloud service provider has already implemented and had assessed a large subset of the NIST 800-53 controls required for your authorization.

A Customer Responsibility Matrix (CRM) is the formal document that maps each of the 421 FedRAMP High controls into one of three categories: controls SecureWatch handles entirely, controls where responsibility is shared, and controls that remain yours.

For your ATO team, this is the single most impactful document in the authorization process. Every fully inherited control is one your 3PAO does not need to independently assess — compressing your authorization timeline by months and reducing assessment costs by tens of thousands of dollars.

Most competing SIEM platforms hold only FedRAMP Moderate authorizations. Inheriting from a High baseline means you receive coverage across more control families, at greater depth, than Moderate-authorized alternatives can provide.

✓ Fully Inherited

SecureWatch implements, operates, and maintains the control entirely. Your ATO package references our authorization — no independent implementation required. Examples: infrastructure encryption, audit log immutability, vulnerability scanning of platform components.

◐ Shared / Partially Inherited

SecureWatch provides the capability; you configure it for your environment. Examples: access control policies (we provide five-role RBAC — you assign roles to your staff), incident response (we provide alerting and playbooks — you staff the response team).

○ Customer Responsible

Controls that fall outside the platform boundary. Examples: physical security of your on-premises endpoints, your organization's security awareness training, personnel screening for your staff.

Key Control Families & Implementations

SecureWatch implements controls across all major NIST 800-53 Rev 5 families. The table below highlights key controls and their platform-level implementations — the full CRM details all 421 controls.

Control Family Key Controls SecureWatch Implementation
AC — Access Control AC-2, AC-3, AC-17 Cognito + login.gov or federated IdP; IAM least-privilege; five-role RBAC; mandatory MFA; per-tenant token scoping via STS
AU — Audit & Accountability AU-2, AU-3, AU-9, AU-12 CloudTrail (all API events), AI provenance engine, WORM-compliant audit log, immutable DynamoDB trail available for 3PAO review
CA — Assessment & Authorization CA-2, CA-7 Automated KSI/OSCAL pipeline; continuous ConMon with real-time drift detection; annual 3PAO assessment
CM — Configuration Management CM-2, CM-6, CM-7, CM-8 Terraform IaC (no manual production changes); DISA STIG automation; Bottlerocket immutable OS nodes; Inspector asset inventory
IA — Identification & Authentication IA-2, IA-5 Login.gov (IAL2/AAL2) or SAML/OIDC federation; PIV/CAC support; per-tenant certificate authority; FIPS-validated credential storage
IR — Incident Response IR-4, IR-5, IR-6 Automated alert routing; GuardDuty threat intel integration; version-controlled response playbooks; 1-hour notification SLA
SA — System Acquisition SA-10, SA-11 CI/CD security gates; SBOM generation; SAST/DAST/SCA pipeline; digitally signed build artifacts
SC — System & Comms Protection SC-8, SC-12, SC-13, SC-28 mTLS everywhere; FIPS 140-2 Level 3 TLS (CloudHSM); per-tenant KMS CMKs; PrivateLink endpoints; zero internet egress
SI — System & Information Integrity SI-2, SI-3, SI-7 Automated patch pipeline; Inspector vulnerability scanning; Wazuh FIM with SHA-256 baselines; sub-second change detection

Compliance Frameworks Supported

SecureWatch's FedRAMP High baseline maps to the most demanding federal compliance frameworks, providing inheritable controls and automated evidence collection across each.

NIST SP 800-53 Rev 5 (High)

Full implementation of 421 High baseline controls with continuous monitoring and automated evidence generation across all control families.

FISMA High

Complete continuous monitoring and annual assessment pipeline. Automated ConMon reporting aligned to OMB requirements.

CMMC Level 2/3

Direct NIST 800-171 mapping with automated evidence collection. Purpose-built for the 300,000+ defense contractors now requiring CMMC compliance.

DFARS 252.204-7012

Adequate security controls for Covered Defense Information. Full audit trail and incident notification capabilities meeting contractor obligations.

DoD IL4/IL5

Reciprocity documentation for streamlined DoD ATO. AWS GovCloud deployment meets Impact Level 4 and 5 data handling requirements.

FedRAMP 20x

Real-time OSCAL artifact generation and KSI monitoring — purpose-built for GSA's transition to machine-readable continuous authorization.

The OSCAL/KSI Automation Pipeline

The Problem

FedRAMP continuous monitoring (ConMon) traditionally requires monthly documentation updates, quarterly control assessments, and evidence gathering that consumes significant compliance staff time. GSA's FedRAMP 20x initiative transitions to machine-readable Key Security Indicators (KSIs) and OSCAL artifacts — but most platforms lack the ability to generate these automatically. Compliance teams spend weeks compiling evidence that was available in real time but trapped in dashboards nobody exports.

SecureWatch's Automated KSI/OSCAL Reporting pipeline translates live platform telemetry directly into machine-readable FedRAMP 20x authorization artifacts. This is not a reporting feature — it is a continuous authorization engine that proves your inherited controls are operational, in real time, without human intervention.

The pipeline runs continuously across your tenant's security telemetry. Every Wazuh alert, every FIM event, every vulnerability scan result, every access control decision is evaluated against NIST 800-53 Rev 5 control families and mapped to the corresponding FedRAMP 20x KSIs. When the evidence confirms a control is working, the system generates a signed artifact proving it. When the evidence goes silent or contradictory, the system fires a drift alert before your PMO review window.

No incumbent SIEM platform generates real-time OSCAL artifacts for continuous authorization. As FedRAMP 20x adoption accelerates — projected 40% marketplace share by 2028, 75% by 2031 — this capability becomes a gating requirement, not a differentiator.

1

Control Mapping

Every incoming telemetry event is evaluated against a real-time mapping of Wazuh detection rules to NIST 800-53 Rev 5 control families and FedRAMP 20x Key Security Indicators. The mapping is maintained as a versioned configuration — when NIST or GSA update control definitions, the mapping updates without code changes.

4,000+ Wazuh rules → 421 NIST 800-53 controls → FedRAMP 20x KSIs
Mapping versioned in Git, deployed via Terraform
2

KSI Status Evaluation

When telemetry confirms a control's operational status, the corresponding KSI status is updated within 15 minutes. The evaluation is evidence-based: a control isn't marked "satisfied" because it was configured — it's marked satisfied because the platform observed it working. FIM events prove SI-7 is operational. Successful MFA challenges prove IA-2. Encrypted transport confirmations prove SC-8.

Evidence-based validation, not configuration-based
15-minute evaluation cycle per control family
3

OSCAL Artifact Generation

For each satisfied KSI, the AI generates a timestamped, structured OSCAL JSON component definition referencing the specific telemetry evidence that confirmed the control's status. The artifact follows the NIST OSCAL specification precisely — it is not a summary or a report, but a machine-readable authorization document that the FedRAMP PMO's automated review pipeline can ingest directly.

Output: OSCAL JSON component-definition per KSI
References: specific event IDs, timestamps, control mappings
Format: NIST OSCAL 1.x specification compliant
4

Digital Signing & Non-Repudiation

Each OSCAL artifact is digitally signed using AWS CloudHSM with FIPS 140-2 Level 3 validated RSA-PSS-SHA-256 algorithms. The signature provides cryptographic non-repudiation: the PMO can verify that the artifact was generated by the SecureWatch platform at the stated time and has not been modified since generation. This is the chain-of-custody guarantee that makes machine-readable authorization trustworthy.

Signing: AWS CloudHSM (FIPS 140-2 Level 3)
Algorithm: RSA-PSS-SHA-256 via AWS Signer
Verification: Public key available in FedRAMP package
5

GRC Feed Delivery

Signed artifacts are delivered to your agency's GRC pipeline automatically. SecureWatch supports three delivery targets out of the box, configurable per tenant. Your compliance team doesn't export, download, or manually submit anything — the artifacts flow from telemetry to PMO without human intervention.

Delivery targets: eMASS API, GovCloud S3, FedRAMP PMO submission queue
Frequency: Continuous (artifacts generated as controls are validated)
Format: Signed OSCAL JSON with provenance metadata

⚠ Drift Detection

If a previously satisfied control's supporting telemetry goes silent or turns contradictory, a drift detection alert fires within 15 minutes — enabling corrective action before the next PMO review window. This is the inverse of the generation pipeline: instead of proving a control works, it proves when a control has stopped working.

Detection Window
≤ 15 minutes from telemetry deviation
Alert Channels
SOC dashboard, email, SOAR webhook
Trigger Conditions
Telemetry silence, contradictory evidence, configuration regression
Resolution Tracking
Timestamped remediation with updated OSCAL artifact on resolution

GRC Delivery Targets

🔗
eMASS API
Direct integration with DoD's Enterprise Mission Assurance Support Service
☁️
GovCloud S3
Signed artifacts deposited to your agency's designated S3 bucket
📋
FedRAMP PMO Queue
Direct submission to GSA's automated review pipeline

Example OSCAL Artifact (Simplified)

// Generated automatically from live telemetry — not manually authored

{
  "component-definition": {
    "uuid": "a7f3c2d1-...",
    "metadata": {
      "title": "SecureWatch KSI Validation — SI-7 File Integrity Monitoring",
      "last-modified": "2026-02-25T14:32:07Z",
      "oscal-version": "1.1.2"
    },
    "components": [{
      "type": "service",
      "title": "Wazuh FIM — SHA-256 Baseline Monitoring",
      "control-implementations": [{
        "implemented-requirements": [{
          "control-id": "si-7",
          "description": "File integrity monitoring active across 2,847 enrolled endpoints. 14,203 FIM events processed in evaluation window. Zero unauthorized modifications detected.",
          "evidence-refs": ["wazuh-fim-550-2026-02-25", "wazuh-fim-554-2026-02-25"]
        }]
      }]
    }],
    "signature": "RSA-PSS-SHA256:4a8b2c..." // CloudHSM FIPS 140-2 L3
  }
}

Why Inheriting from FedRAMP High Matters

Most competing SIEM platforms — Splunk, CrowdStrike, Elastic — hold only FedRAMP Moderate authorizations. That limits what you can inherit.

421

Controls Implemented

FedRAMP High implements 421 NIST 800-53 Rev 5 controls — significantly more than the ~325 required for Moderate. Every additional control you inherit is one you don't independently assess.

1.4×

Incremental Cost, Not 2×

The cost of High over Moderate is approximately 1.4× because many High controls are enhancements to existing Moderate controls — not entirely new families. The "Moderate-then-upgrade" path costs nearly as much while delaying access to the most valuable market.

DoD

Required for High-Impact

FedRAMP High authorization is required for DoD systems and high-impact civilian environments. If you're pursuing DoD ATO or handling high-impact data, inheriting from a Moderate CSP doesn't cover your requirements.

Authorization Level Comparison

SecureWatch and Microsoft Sentinel are the only SIEM platforms in this competitive set with FedRAMP High authorization. The difference: our AI is included, not an add-on.

Capability
SecureWatch
Splunk Cloud
Elastic Cloud
MS Sentinel
CrowdStrike
FedRAMP Level
✓ HIGH
✓ High
DoD IL4/IL5
✓ Supported
Limited
Limited
✓ Supported
Limited
OSCAL/KSI Automation
✓ Real-Time
✗ None
✗ None
Limited
✗ None
Built-In AI / LLM
✓ Included
CRM / Inheritance Docs
✓ Available
Available
Available
Available
Available
421 High Controls
✓ Full
✗ Moderate
✗ Moderate
✓ Full
✗ Moderate
Continuous Drift Detection
✓ ≤15 min
✗ Manual
✗ Manual
✗ Manual
✗ Manual

Ready to Accelerate Your Authorization?

The complete CRM and FedRAMP High control inheritance documentation package is available for organizations building their own authorization packages.

Compliance Package (CRM + Inheritance): $7,500 one-time · Includes full 421-control mapping with implementation details