Annual assessment and authorization maintenance

The annual assessment and authorization maintenance requirement means you must keep your FedRAMP authorization current by completing periodic assessments and refreshing evidence so the Authorizing Official can continue to trust your security posture. Operationally, run an annual assessment program, keep core authorization artifacts updated, and prove control performance with audit-ready evidence. ¹

Key takeaways:

• Treat “annual assessment” as a recurring operational cycle: scope, test, remediate, and report with dated evidence. ¹
• Keep the authorization package “evergreen” by updating SSP, inventories, and plans when the system changes, not only before an assessment. ¹
• Your biggest risk is evidence gaps: controls may exist, but without timely artifacts you can’t demonstrate ongoing compliance. ¹

This requirement is easy to misunderstand because “annual assessment” sounds like a once-a-year event. In FedRAMP operations, it is better managed as a continuous authorization maintenance program where the annual assessment is the scheduled validation point. Your job, as a Compliance Officer/CCO/GRC lead, is to make ongoing compliance visible, testable, and defensible through refreshed evidence and well-controlled change.

FedRAMP’s baseline expectation is straightforward: sustain authorization through periodic assessments and evidence refresh. ¹ That translates into three operational outcomes: (1) you plan and execute the annual assessment with defined scope and ownership; (2) you continuously maintain authorization artifacts so they match reality; and (3) you can produce assessor- and AO-ready evidence on demand.

This page gives you requirement-level implementation guidance you can act on quickly: applicability, step-by-step execution, evidence to retain, audit questions, common failure modes, and a practical 30/60/90-day plan. It assumes you already operate a FedRAMP-authorized (or FedRAMP-in-process) cloud service and need to keep authorization from degrading over time. ¹

Requirement: annual assessment and authorization maintenance requirement (FedRAMP)

Operator intent: Maintain your FedRAMP authorization by (a) performing periodic assessments and (b) refreshing evidence so the authorization package reflects the current system and control performance. ¹

## Regulatory text

Provided excerpt: “Sustain authorization through periodic assessments and evidence refresh.” ¹

What this means for you, in plain English

• You don’t “get authorized” once and stop. You must keep proving the system still meets the baseline over time through recurring assessment work and updated artifacts. ¹
• Your evidence needs to be current enough that an AO (or assessor) can trace: system boundary → control implementation → operating evidence → findings/remediation status. ¹

Related framework anchor

• FedRAMP baselines map to NIST SP 800-53 controls; your annual assessment activity should align to the control set in your authorization boundary and baseline level. ²

Who this applies to

Entities

• Cloud Service Providers (CSPs) operating a FedRAMP-authorized system or pursuing FedRAMP authorization. ¹

Operational context where this shows up

• You have an Authority to Operate (ATO) or equivalent authorization decision that depends on continued control performance and timely reporting. ¹
• You make frequent system changes (patching, deployments, scaling, new services, new logging pipelines) that can invalidate documentation or control operation if not governed. ¹
• You rely on third parties (including cloud infrastructure providers, security tooling providers, outsourced operations) whose changes can impact inherited controls and evidence. ¹

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

Use this as your operating checklist for authorization maintenance. Keep each step owned, dated, and evidenced.

1) Establish the annual assessment governance (program owner + calendar)

1. Assign a single accountable owner for authorization maintenance (typically GRC) and identify required contributors: security engineering, IT/ops, product, and key third parties. ¹
2. Create an “authorization maintenance calendar” that includes: assessment planning, evidence collection windows, internal testing, remediation windows, and package update deadlines. ¹
3. Define entry/exit criteria for “assessment ready,” such as: SSP updated to current architecture, inventories reconciled, open findings triaged, and evidence repository complete. ¹

Operator tip: If you can’t name the owner of each major artifact (SSP, control implementation statements, inventories, plans), you will miss refresh cycles.

2) Freeze and confirm assessment scope (boundary and control set)

1. Confirm the system boundary and external dependencies (including third-party services) match what’s documented. ¹
2. Confirm the applicable baseline/control set you are assessing against is the one in your current authorization package. ¹
3. Create a test plan and evidence request list that maps each in-scope control to the expected evidence type (policy, procedure, technical output, tickets, logs, screenshots, configurations). Align the mapping to NIST SP 800-53 control language to reduce ambiguity with assessors. ²

3) Refresh “evergreen” authorization artifacts before evidence collection

Do this early. Evidence collection goes faster when documentation already reflects reality.

Refresh, at minimum:

• System Security Plan (SSP): architecture diagrams, data flows, boundary definitions, control implementation narratives. ¹
• Asset and inventory records: systems, components, software, and relevant third-party integrations within boundary. ¹
• Plans of action: open items and remediation plans, with owners and status. ¹

Practical rule: If engineering says “that diagram is outdated,” treat it as a compliance incident. Fix the artifact first, then collect evidence.

4) Collect evidence the way an assessor will review it

1. Centralize evidence in a controlled repository with consistent naming (control ID, date, system, owner). ¹
2. For each control, collect evidence that shows operation, not just intent. Policies alone rarely prove a control is working. ¹
3. Record context for each artifact: what it demonstrates, what system it comes from, and how it ties to the control implementation statement. ¹

Examples of “operation” evidence

• Access reviews: tickets/approvals, IAM exports, reviewer sign-off records.
• Logging/monitoring: SIEM rule configs, alert evidence, incident tickets.
• Vulnerability management: scan outputs, remediation tickets, exception approvals.

(Examples are implementation patterns; maintain alignment to your FedRAMP package.) ¹

5) Execute internal readiness testing and gap triage

1. Run a pre-assessment control walkthrough with control owners to validate: evidence exists, evidence is current, and evidence matches the documented implementation. ¹
2. Log gaps as findings with severity, owner, and remediation plan; connect them to your POA&M process so tracking is consistent. ¹
3. Resolve “documentation drift” immediately: update SSP/inventories to match the deployed environment, then re-collect evidence if needed. ¹

6) Support the annual assessment and close out results

1. Provide the assessor with a traceable package: control-to-evidence mapping, artifact index, and any approved exceptions with rationale. ¹
2. Track assessment outputs (findings, recommendations) through closure, and keep the authorization artifacts synchronized with remediation outcomes. ¹
3. Communicate material changes and risk items to your authorizing stakeholders using the same language as the authorization package. ¹

Required evidence and artifacts to retain

Maintain artifacts in a way that you can produce them quickly with clear lineage and dates.

Core artifacts (evergreen)

• Current SSP and architecture diagrams ¹
• System boundary definition and dependency list, including third parties ¹
• Inventories relevant to control scope (assets, software, accounts as applicable) ¹
• POA&M / remediation tracker with status and ownership ¹

Assessment artifacts

• Annual assessment plan and scope statement ¹
• Control-to-evidence mapping (crosswalk) aligned to the baseline control set ²
• Evidence repository index (what, where, owner, date) ¹
• Internal readiness review notes and approvals ¹

Change evidence (authorization maintenance glue)

• Change records for boundary-impacting changes and updates to the SSP reflecting those changes ¹
• Third-party change notices (where applicable) and your impact assessments ¹

Common exam/audit questions and hangups

Expect these lines of questioning and prepare “show me” answers.

1. “Show me how you ensure the SSP reflects the deployed environment.”
   Hangup: teams update docs only before an assessment; auditors want ongoing control. ¹

2. “How do you prove controls were operating throughout the period, not just today?”
   Hangup: evidence snapshots without time context; missing dated records and approvals. ¹

3. “How do you manage boundary changes and third-party dependencies?”
   Hangup: undocumented inherited controls or untracked dependency drift. ¹

4. “Walk me from a finding to remediation to package update.”
   Hangup: POA&M exists, but doesn’t tie to change tickets, validation evidence, and updated control narratives. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	What it looks like	How to avoid it
Treating the annual assessment as a scramble	Evidence collected in the last minute, lots of “tribal knowledge”	Run a standing authorization maintenance calendar and monthly evidence check-ins. 1
Documentation drift	SSP and diagrams don’t match current architecture	Put SSP updates into the change process: “no close” on boundary changes until SSP updates are merged. 1
Evidence without traceability	Files exist but can’t be mapped to controls	Maintain a control-to-evidence index with owners and dates. 1
Control owners don’t own evidence	GRC chases artifacts across teams	Assign control owners and require evidence submission as part of operational SOPs. 1
Third-party blind spot	Inherited controls assumed, not validated	Track third-party dependencies in the boundary and maintain impact assessments for changes. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page focuses on operational and authorization risk rather than penalties or case outcomes. The practical risk is loss of confidence by authorizing stakeholders if you cannot demonstrate ongoing control performance and up-to-date authorization artifacts. ¹ That risk concentrates in two places: evidence freshness and change management discipline. ¹

Practical 30/60/90-day execution plan

This plan assumes you need to stand up (or stabilize) an authorization maintenance program quickly.

Days 0–30: Stabilize scope, owners, and evidence plumbing

• Assign owners for SSP, inventories, POA&M, and evidence repository administration. ¹
• Build your annual assessment calendar and define “assessment ready” criteria. ¹
• Create a control-to-evidence mapping template aligned to your in-scope baseline controls (map to NIST SP 800-53 language). ²
• Stand up a centralized evidence repository with naming conventions and access controls. ¹

Where Daydream fits: Daydream can act as the system of record for requirement-to-evidence mapping and recurring evidence requests, so control owners get predictable asks and you get consistent traceability.

Days 31–60: Refresh artifacts and run a readiness drill

• Update SSP sections most likely to drift: architecture, boundary, data flows, and control implementation narratives tied to recent changes. ¹
• Reconcile inventories (assets/components and third-party dependencies) against production reality. ¹
• Run a readiness drill: pick a subset of high-friction controls and perform an assessor-style walkthrough from narrative → evidence → operating proof. ¹
• Open POA&M items for gaps; assign remediation owners and target dates based on risk. ¹

Days 61–90: Execute continuous cadence and pre-stage the annual assessment

• Set a recurring evidence refresh cadence per control owner team (for example, monthly for operational evidence-heavy controls and quarterly for policy/procedure confirmations; cadence is your governance choice). ¹
• Implement a “change-to-SSP” gate for boundary-impacting changes so documentation stays current. ¹
• Prepare the assessment package binder: scope statement, evidence index, control mapping, and POA&M status summary. ¹
• Run a second walkthrough focused on previously identified gaps to confirm remediation evidence is clean and traceable. ¹

Frequently Asked Questions

What counts as “evidence refresh” for authorization maintenance?

Refresh means updating artifacts so they reflect the current system and current control operation, not last year’s environment. Typical refresh includes SSP updates, inventory reconciliation, and new dated operational evidence tied to in-scope controls. ¹

Do we only update the SSP once a year for the annual assessment?

No. If your system changes, your SSP and supporting artifacts need to change with it so the authorization package stays accurate. Treat SSP updates as part of operational change control, then the annual assessment becomes validation instead of archaeology. ¹

How do we keep third-party dependencies from breaking our authorization maintenance?

Maintain an explicit dependency list in the system boundary and require impact assessment when those third parties change services, configurations, or assurance artifacts you rely on. Store the impact assessments with your evidence so you can show how you evaluated inherited control impacts. ¹

What is the single fastest way to fail an annual assessment readiness review?

Documentation drift paired with weak evidence traceability. If an assessor cannot map your current implementation narrative to dated, specific evidence, you end up debating intent instead of demonstrating operation. ¹

Who should own authorization maintenance: security, compliance, or engineering?

GRC typically owns coordination and package integrity, while engineering/security own control operation and producing evidence. Make ownership explicit per artifact and per control family so evidence collection doesn’t depend on informal relationships. ¹

We have evidence, but it’s scattered across tools. Is that acceptable?

It can be, but you need a durable index that maps controls to evidence locations, owners, and dates so you can produce a coherent assessment package quickly. Centralizing the index (and, where possible, the evidence) reduces missed artifacts and inconsistent versions. 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. NIST SP 800-53 Rev. 5