Authorization package readiness

Authorization package readiness requirement means you must be able to produce a complete, internally consistent FedRAMP authorization package (SSP, control narratives, and supporting evidence) that a 3PAO and authorizing officials can review without gaps or rework. Operationalize it by running your SSP like a controlled product: standardized narratives, an evidence index mapped to controls, and a readiness review process tied to change management.

Key takeaways:

• Treat the SSP, control narratives, and evidence as one integrated “package,” not separate documents.
• Build an evidence index that maps each control to specific, current artifacts and owners ¹.
• Readiness is a continuous state; if changes are not reflected in the SSP and evidence set, the package will fail review.

Compliance leaders often underestimate why FedRAMP packages stall: not because controls are missing, but because the system documentation and evidence trail cannot prove what engineering says is true. The authorization package readiness requirement is simple on paper and unforgiving in practice. You are expected to prepare a complete System Security Plan (SSP), control implementation narratives, and an evidence package suitable for authorization review ¹.

For a CCO or GRC lead, the operational challenge is coordination and precision. Your package has to line up across three layers: (1) what the system is (architecture, boundary, data flows), (2) what controls are implemented (narratives, parameters, inherited responsibility), and (3) what evidence proves it (configs, screenshots, tickets, policies, logs, reports). If any layer conflicts with another, reviewers slow down, ask for clarification, and your team burns cycles chasing document drift.

This page gives requirement-level implementation guidance you can execute quickly: who owns what, what to build, how to structure the evidence set, and how to run readiness reviews so the package stays current through change. References point to FedRAMP templates and NIST SP 800-53 Rev. 5, since your package narratives and evidence should map to the control baseline ².

Regulatory text

FedRAMP requirement (FEDRAMP-01): “Prepare complete SSP, control narratives, and evidence package for authorization.” ¹

What the operator must do:

• Produce an SSP that accurately describes the authorized system boundary, components, interconnections, roles, and how each baseline control is implemented.
• Provide control narratives (implementation statements) that are specific to your environment and consistent with the SSP and architecture.
• Assemble an evidence package that substantiates the narratives with dated, attributable artifacts that a reviewer can validate.
  This work is typically executed using FedRAMP’s published documents and templates, and it should align control intent and structure to NIST SP 800-53 Rev. 5 ².

Plain-English interpretation

The authorization package readiness requirement exists to prevent “trust me” security. You are not done when controls are built. You are done when you can prove, in a reviewable and repeatable way, that controls are implemented for the specific system seeking authorization.

Readiness has three practical tests:

1. Completeness: every applicable control has a narrative and mapped evidence.
2. Consistency: architecture diagrams, inventory, boundary, and narratives agree with each other.
3. Recency and traceability: evidence is current enough to reflect the production environment and is attributable to a source (system export, tool report, ticket, or signed record) with clear ownership.

Who it applies to (entity and operational context)

Applies to: Cloud Service Providers (CSPs) preparing for FedRAMP authorization or maintaining an authorization that will be assessed on an ongoing basis ¹.

Operational context where it shows up:

• You are preparing for a readiness assessment, a 3PAO assessment, or an authorization decision.
• You are updating an existing package after major changes (new regions, new identity provider, new logging pipeline, new boundary).
• You are responding to reviewer questions about gaps, inconsistencies, or unclear inheritance/responsibility splits.

Teams involved: GRC, security engineering, platform/infra, IAM, networking, SecOps, product, and any third parties providing inherited controls (for example, IaaS/PaaS providers or managed security tooling). Your package must clearly show which controls you implement versus inherit, consistent with FedRAMP documentation expectations ¹.

What you actually need to do (step-by-step)

1) Lock the system boundary and authorization scope

• Confirm the system boundary (in-scope components, environments, regions, tenants) and document it consistently across the SSP, diagrams, inventory, and data flows.
• Identify external services and interconnections and decide whether they are in-scope, out-of-scope, or inherited.
• Establish a single source of truth for “what is in the system,” typically a controlled inventory and architecture package referenced by the SSP.

Operator tip: Most package churn comes from boundary ambiguity. Resolve boundary decisions before polishing narratives.

2) Build the SSP as a controlled deliverable

• Use FedRAMP’s SSP template structure so reviewers see familiar sections and control organization ¹.
• Make every control narrative answer three questions:
  1. What is implemented (mechanism and configuration),
  2. Where it is implemented (specific system components/tools), and
  3. Who operates it (role/team, with operational frequency described qualitatively if you cannot source exact intervals).
• For inherited controls, state the inheritance source and how you validate the inheritance assumptions.

Quality bar: Narratives should be specific enough that a technical reviewer can follow them to the evidence without guessing.

3) Create a control-to-evidence index (your package “map”)

Maintain a living evidence index that maps:

• Control ID / enhancement (aligned to the baseline) ³
• Narrative location (SSP section reference)
• Evidence artifact name
• Evidence type (policy, screenshot, export, config, ticket, report)
• System/component source
• Owner (person/team)
• Date collected / version
• Notes on applicability or inheritance

This index is the fastest way to show “nothing is missing” and to manage updates without rework ¹.

4) Collect evidence that proves operation, not just design

Bias toward evidence that demonstrates controls are active in the production-like environment:

• Tool exports or reports (logging, vulnerability scanning, SIEM alerts, IAM configuration)
• Change tickets showing approvals and implementation
• Access reviews, incident records, and operational runbooks
• Policies and procedures that match what engineering actually does

Common reviewer reaction: A policy without corroborating system proof reads as intent, not implementation.

5) Run an internal “readiness review” before any external assessment

Create a structured, cross-functional review with three checks:

• Cross-document consistency: boundary, diagrams, inventory, and narratives agree.
• Evidence sufficiency: each control has evidence that directly supports the narrative.
• Traceability: each artifact has an owner and can be regenerated on request.

Practical method: pick a sample of controls across families and conduct “walkthroughs” where the owner opens the evidence source live and explains how it maps to the narrative.

6) Tie package maintenance to change management

Authorization packages fail when they freeze documentation while the system keeps changing. Add a required step to change management:

• If a change affects boundary, architecture, identity, logging, encryption, interconnections, or major services, it triggers SSP/narrative updates and evidence refresh.

Daydream note (earned mention): teams that track controls, narratives, and artifacts in disconnected spreadsheets often lose traceability after reorganizations or tooling changes. Daydream can act as the control-and-evidence system of record so your evidence index, ownership, and refresh workflow stay intact during package evolution.

Required evidence and artifacts to retain

Keep artifacts in a controlled repository with versioning and access controls. Your minimum set should include:

Core package artifacts

• FedRAMP SSP (current version) ¹
• Control implementation narratives (embedded in SSP or controlled companion)
• Evidence index (control-to-artifact map)

Boundary and architecture proof

• System boundary statement and scoping decisions
• Current architecture diagrams and data flow diagrams
• Inventory of in-scope components and services

Control evidence (examples)

• IAM configuration exports and role mappings
• Logging/monitoring configurations and sample outputs
• Vulnerability management outputs and remediation tracking
• Incident response records and after-action documentation
• Configuration baselines and secure build artifacts
• Policies/procedures that match operational reality

Retention principle: Store “how you know” artifacts. If a reviewer asks, you should be able to reproduce the claim from the evidence source.

Common exam/audit questions and hangups

Expect reviewers, assessors, and internal audit to probe:

• “Show me where this control is implemented.” If the narrative names a tool, the evidence must come from that tool (or a traceable export).
• “What changed since the last package update?” If you cannot answer quickly, your package maintenance process is weak.
• “What is inherited vs. implemented by you?” Ambiguity here creates gaps and duplicate work.
• “Do diagrams match reality?” Mismatched regions, endpoints, or service names signal documentation drift.
• “Can the control owner explain the evidence?” Evidence that only GRC understands is fragile; ownership must sit with operators.

Frequent implementation mistakes and how to avoid them

1. Generic narratives copied from templates

   • Fix: rewrite narratives to name your actual components, identity flows, logging destinations, and responsible teams ¹.

2. Evidence that proves a policy exists, but not that the control operates

   • Fix: pair each policy with operational proof (exports, tickets, logs) tied to the narrative.

3. No single evidence index

   • Fix: maintain one authoritative control-to-evidence index and require updates when evidence is refreshed.

4. Boundary creep during assessment

   • Fix: treat scope changes as a formal decision that updates SSP, diagrams, and evidence together.

5. Orphaned ownership

   • Fix: assign an owner per control family or control cluster and make owners responsible for evidence regeneration.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied sources, so this page does not list specific actions or outcomes.

Operationally, the risk is still concrete: incomplete or inconsistent authorization packages delay authorization decisions, increase assessor questions, and create rework loops. The most common failure mode is not “no control exists,” but “the package cannot prove the control implementation for this system boundary” ¹.

Practical 30/60/90-day execution plan

Days 0–30: Stabilize scope and build the package backbone

• Confirm system boundary, external dependencies, and inheritance assumptions.
• Stand up the SSP in FedRAMP template format and define narrative standards (what each narrative must include) ¹.
• Create the evidence index structure and assign control owners.
• Run a pilot on a subset of controls to validate evidence quality and traceability.

Days 31–60: Populate narratives and evidence, then pressure-test

• Complete control narratives across the baseline, aligned to NIST SP 800-53 Rev. 5 structure ³.
• Collect evidence for each control and record it in the evidence index.
• Perform internal walkthroughs: control owner demonstrates evidence live, GRC validates mapping to narrative.
• Resolve consistency defects across diagrams, inventory, and SSP.

Days 61–90: Operationalize maintenance and readiness reviews

• Implement a recurring readiness review process triggered by material changes.
• Integrate SSP/evidence updates into change management so documentation drift is caught early.
• Prepare a reviewer Q&A pack: scope statement, inheritance summary, evidence index, and known limitations with remediation plans.
• If using Daydream, configure control ownership, evidence tasks, and artifact traceability workflows so readiness becomes routine rather than a scramble.

Frequently Asked Questions

What does “complete SSP” mean in practice?

It means the SSP matches the real system boundary and includes control implementation statements that a reviewer can trace to evidence. Completeness is measured by “no missing controls and no undocumented scope components” ¹.

Can we submit policies as evidence for most controls?

Policies are necessary but rarely sufficient. Reviewers typically expect technical proof that controls operate in the environment described in the SSP, such as configuration exports, logs, or tickets tied to the named systems ¹.

How do we handle inherited controls from cloud providers or third parties?

Document inheritance explicitly in the narrative and identify the inheritance source in a way that aligns with FedRAMP documentation expectations. Keep evidence of how you validate the inheritance assumptions and where your shared responsibility begins ¹.

Who should own the authorization package readiness requirement?

GRC should own the package integrity (structure, consistency, submission readiness), while engineering and operations own the truth of narratives and the ability to regenerate evidence. Assign named owners for evidence production and refresh to prevent orphaned controls.

What is the fastest way to reduce assessor questions?

Make the evidence index your primary navigation layer, then run internal control walkthroughs where operators demonstrate evidence directly from source systems. This catches mismatches between narratives and reality before a 3PAO does ¹.

How do we keep the package current while the product changes weekly?

Tie SSP and evidence updates to change management triggers for boundary, architecture, identity, logging, encryption, and interconnections. Treat the SSP and evidence index as living artifacts with controlled updates ¹.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. FedRAMP Baseline Documentation

2. FedRAMP Baseline Documentation; NIST SP 800-53 Rev. 5

3. NIST SP 800-53 Rev. 5