Vulnerability scanning and remediation SLAs

The vulnerability scanning and remediation SLAs requirement means you must run the vulnerability scans FedRAMP expects for your cloud system and fix (or formally accept) findings within defined timeframes. To operationalize it, set explicit severity-based remediation SLAs, measure aging against those SLAs, and maintain documented exceptions with risk acceptance and compensating controls ¹.

Key takeaways:

• Define scanning scope and cadence across the full FedRAMP authorization boundary, including cloud and supporting components ¹.
• Enforce severity-based remediation SLAs with ownership, tracking, and an exception workflow tied to risk acceptance ¹.
• Retain audit-ready evidence: scan outputs, tickets, SLA-aging dashboards, exception approvals, and closure verification mapped to the system boundary ².

For a FedRAMP cloud service provider, vulnerability scanning is not a “security best practice” you can do informally. It is a repeatable compliance obligation: perform mandated scanning routines, then remediate findings within expected timeframes, and prove both with clean evidence ¹. Auditors and 3PAOs typically focus on two things: coverage (did you scan everything in-scope, on schedule?) and timeliness (did you fix issues within your defined SLA, or document why you didn’t?).

This requirement becomes operationally hard in common real-world conditions: teams scan but don’t scan the full boundary; findings land in multiple queues; severity ratings are inconsistent; “exceptions” live in email threads; closure is reported without validation. The fix is governance and plumbing: define SLAs, wire scanner output into ticketing, require closure evidence, and produce a simple aging view that tells you what is late, why, and who approved the residual risk.

This page gives requirement-level implementation guidance you can put into motion quickly, aligned to FedRAMP expectations and mapped to widely used NIST control language for vulnerability management evidence ³.

Regulatory text

FedRAMP requirement (excerpt): “Run mandated scanning routines and remediate findings within expected timeframes.” ¹

Operator meaning: you must (1) run the vulnerability scans FedRAMP expects for your environment, (2) track findings through remediation, and (3) meet defined remediation timelines or document approved exceptions, with evidence that an assessor can validate ¹. NIST SP 800-53 Rev. 5 provides the control framework commonly used to describe and evidence vulnerability monitoring and remediation activities in federal security programs ⁴.

Plain-English interpretation (what the requirement is really testing)

This requirement tests whether your vulnerability program is controlled, measurable, and enforceable:

• Controlled: scanning is scheduled, repeatable, and scoped to the authorization boundary, not run ad hoc by individual teams ¹.
• Measurable: you can show coverage, findings by severity, and time-to-remediate trends ¹.
• Enforceable: findings have owners, deadlines, and consequences (escalation), plus a formal exception path when remediation is not immediately feasible ¹.

If you cannot answer “what’s currently overdue, why, and who accepted the risk,” you will struggle to evidence compliance during assessment or continuous monitoring.

Who it applies to (entity and operational context)

Applies to: Cloud Service Providers pursuing or maintaining FedRAMP authorization ¹.

Operational context: Any environment and components inside your FedRAMP system boundary, including:

• Compute, OS images, containers, endpoints used to administer the environment
• Network devices and security appliances
• Managed services where you retain vulnerability responsibility, plus shared-responsibility components where you must show oversight and compensating controls ¹

If you rely on third parties (including managed scanning providers or MSSPs), you still own the compliance outcome. You can outsource execution; you cannot outsource accountability.

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

1) Define your scanning scope (authorization boundary first)

1. List all in-scope asset types: servers, containers, databases, network devices, hypervisors (if applicable), CI/CD runners, bastions, admin workstations used to manage the boundary.
2. Map assets to a system inventory so scan coverage can be tested against “what exists,” not “what the scanner saw.”
3. Document inclusions/exclusions and the reason (for example, “appliance is vendor-managed; we validate via attestation + compensating controls”) ¹.

Deliverable: a scan scope statement tied to the FedRAMP boundary description (SSP-aligned), plus an asset-to-scan mapping.

2) Standardize scanner configuration and operating procedures

1. Choose scanner types appropriate to your architecture: infrastructure vulnerability scanning, web application scanning, container image scanning, and dependency/SCA scanning if those are part of your delivery model (describe what you run and why).
2. Set configuration baselines: authenticated vs. unauthenticated scanning rules, credential handling, scan profiles by environment, and rules for false positive triage.
3. Write an SOP: who runs scans, how often they run, where results are stored, and how failures are handled (retries, escalation, and documenting “missed scans”) ¹.

Evidence tip: auditors often ask for proof of successful execution (scan job history), not just a policy.

3) Create severity-based remediation SLAs that you can enforce

1. Define severity levels (Critical/High/Medium/Low) and your internal method for assigning severity (scanner rating, CVSS inputs, environmental adjustments).
2. Set remediation SLAs per severity as an internal standard. Keep them simple enough to measure consistently.
3. Define SLA start/stop rules:
   • Start: when the finding is confirmed (post-triage), or when first detected (if you treat scanner output as confirmed).
   • Stop: when fix is deployed and verified (rescan/validation), not when a ticket is moved to “resolved.”
4. Set escalation triggers for overdue items (security leadership notification, change management priority, and documented risk acceptance when deadlines cannot be met).

FedRAMP’s excerpt requires remediation within “expected timeframes,” so your burden is to show the timeframes exist, are reasonable, and are followed or formally excepted ¹.

4) Wire findings into a single workflow (ticketing + ownership)

1. Auto-create tickets from scanning tools into your ticketing system.
2. Assign ownership based on asset/service owner, not the security team.
3. Require minimum ticket fields:
   • Unique finding ID and source tool
   • Asset identifier and environment
   • Severity and rationale
   • SLA due date (calculated)
   • Fix plan and change reference
   • Closure evidence requirement (rescan ID, patch version, config diff)
4. Track exceptions in the same system or in a linked risk register entry.

5) Build the SLA-aging view your assessor will request

Create a dashboard or report that shows:

• Coverage: in-scope assets vs. scanned assets, plus scan success/failure logs
• Findings aging by severity: open, due soon, overdue
• Mean time to remediate by severity (qualitative trending is fine if you avoid unsourced numbers)
• Exceptions: count/list, approval authority, expiry/review date, compensating controls ¹

This directly supports the recommended control outcome: “Track scan coverage, severity aging, and remediation exceptions.” ¹

6) Implement an exception (risk acceptance) process that survives audit

A compliant exception process is not “we’ll fix later.” It is:

1. A written request tied to a specific finding or class of findings.
2. Risk analysis specific to your environment (exposure, exploitability, affected data).
3. Compensating controls (WAF rule, segmentation, feature flag, monitoring alert).
4. Approval by the right authority (security/risk owner with delegated authority).
5. Time-bound review (expiry or scheduled review) and a closure plan.

Keep exceptions rare and well-justified; assessors tend to scrutinize patterns.

7) Verify remediation (trust but verify)

Require evidence that the vulnerability is actually gone:

• Rescan results showing closure
• Patch/configuration proof (change record, version output, IaC PR)
• For code issues: commit link + redeployment artifact + SAST/SCA re-check outputs ⁴

Required evidence and artifacts to retain (audit-ready checklist)

Keep artifacts in a system that preserves timestamps and change history:

• Vulnerability management policy and scanning/remediation SOP ¹
• Scan schedules, configurations, and job execution logs ¹
• Raw scan reports/exports for sampled periods
• Ticket records with due dates, ownership, and closure evidence
• SLA-aging dashboards or recurring metrics reports ¹
• Exception/risk acceptance records, approvals, compensating controls, and review outcomes
• Evidence of remediation verification (rescan IDs, change records, patch levels) ⁴
• Boundary-aligned asset inventory and scan coverage mapping

Common exam/audit questions and hangups (what assessors drill into)

1. “Show me the in-scope boundary and prove scan coverage aligns to it.” Expect sampling and reconciliation between inventory and scanner targets ¹.
2. “What are your remediation SLAs, and are they consistently applied?” Inconsistent severity scoring is a common failure mode.
3. “How do you handle missed scans?” You need a documented failure path and evidence of follow-up runs.
4. “Prove closure.” “Ticket closed” is weak without validation proof ⁴.
5. “Explain exceptions.” Who approved, what compensating controls exist, and when the exception expires ¹.

Frequent implementation mistakes and how to avoid them

• Mistake: scanning but not tracking coverage. Fix: reconcile scanner scope against inventory and produce a coverage report each cycle ¹.
• Mistake: SLAs exist in a policy but not in ticket due dates. Fix: compute due dates automatically in ticketing; treat due date as the control point.
• Mistake: exceptions live outside governance. Fix: require a risk register entry and approval workflow for every exception ¹.
• Mistake: closing findings without verification. Fix: make rescan/validation evidence a closure gate ⁴.
• Mistake: third-party or managed service blind spots. Fix: document shared responsibility, obtain evidence from third parties, and implement compensating monitoring within your boundary.

Enforcement context and risk implications

No specific public enforcement cases were provided for this requirement in the source materials. Practically, failure modes here increase the likelihood of exploitable exposure inside your FedRAMP boundary, and they create assessment risk because assessors test repeatability, timeliness, and evidence quality ¹.

Practical 30/60/90-day execution plan

First 30 days (stabilize the basics)

• Confirm the authorization boundary and produce an in-scope asset inventory view aligned to it ¹.
• Document scanning SOPs and standard scan profiles.
• Define remediation SLAs by severity and implement due-date logic in ticketing.
• Stand up a basic SLA-aging report: open findings by severity, due, overdue, and exceptions ¹.

Days 31–60 (make it measurable and auditable)

• Automate ticket creation from scanners and enforce required fields.
• Add verification gates: rescan IDs or configuration evidence required before closure ⁴.
• Implement the formal exception workflow with required approvals and compensating controls.
• Run an internal “mock 3PAO sampling”: pick a sample of assets and findings and test evidence completeness end-to-end.

Days 61–90 (harden operations and reduce noise)

• Tune severity scoring and false-positive workflows so SLA tracking reflects real risk.
• Add coverage reconciliation reporting and missed-scan handling procedures.
• Trend remediation performance and hold regular vulnerability review meetings with service owners.
• Consider a governance platform such as Daydream to centralize evidence collection, exception approvals, and SLA-aging views across teams, so audit requests become a data pull instead of a manual scramble.

Frequently Asked Questions

Do FedRAMP vulnerability scanning and remediation SLAs require specific remediation timelines?

The provided FedRAMP excerpt requires remediation within “expected timeframes,” so you must define timeframes you can defend and then show consistent adherence or documented exceptions ¹. Keep them severity-based and measurable in ticketing.

What counts as “remediated” for audit purposes?

Treat a finding as remediated only after you can verify the fix, typically via a rescan or equivalent technical validation evidence tied to the ticket ⁴. “Patched” without proof usually fails sampling.

How do we handle vulnerabilities we cannot patch quickly due to operational constraints?

Use a formal exception with risk acceptance, compensating controls, approval evidence, and a review/expiry point documented in the same system as the finding ¹. Make exceptions traceable and time-bound in practice.

Do third parties change our obligations for scanning and SLAs?

They change execution, not accountability. If a third party manages components in your boundary, document responsibilities and retain evidence of their scanning/remediation performance or your compensating controls ¹.

How should we show scan coverage to a 3PAO?

Provide an inventory-to-scan reconciliation: a list of in-scope assets and proof each was included in the scan scope and had successful scan runs, plus documented handling for failures ¹.

Our scanner output is noisy. Can we adjust severity or mark findings as false positives?

Yes, but document the triage rationale and keep it consistent. Auditors look for repeatable criteria and evidence that triage is reviewed and approved, especially for high-severity downgrades 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 lifecycle management

Footnotes

1. FedRAMP Baseline Documentation

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

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

4. NIST SP 800-53 Rev. 5