Section 6.02 - Reference Brief
DOC-REF: FRC-3PAO-001
Choosing a FedRAMP 3PAO
Your Third Party Assessment Organization (3PAO) is the single largest variable in your FedRAMP authorization cost and timeline. A well-matched 3PAO with strong SAR quality can cut agency review time significantly. A poor fit can add 6-12 months and hundreds of thousands in additional cost.
Direct Answer
How much does a 3PAO assessment cost?
As an indicative 2026 range, a 3PAO initial assessment costs $100K to $200K at FedRAMP Low, $350K to $650K at Moderate, and $700K to $1.2M+ at High. Annual continuous-monitoring assessments run roughly $30K to $60K (Low), $80K to $150K (Moderate), and $150K to $300K+ (High). 3PAOs do not publish rate cards, so treat these as planning bands rather than quotes: the actual fee turns on system complexity, boundary size, component count, and how much of the control set is inherited from an authorized IaaS. The register below breaks the bands down by impact level.
Section A. Fee Register
3PAO fee ranges by impact level
FedRAMP Low
Narrower scope; fewer controls to test. Some 3PAOs charge less for Low due to simplified documentation and testing.
FedRAMP Moderate
Most competitive market segment. Wide variation based on system complexity, number of components, and boundary scope.
FedRAMP High
Fewer 3PAOs are accredited for High impact. Fees are higher and less negotiable. Cleared-personnel requirements may apply.
Section B. Evaluation Criteria
Eight criteria for selecting a 3PAO
Apply these criteria during 3PAO shortlisting and final selection. Importance is graded as Critical, High, or Medium.
FedRAMP Accreditation Status
CriticalVerify the 3PAO's accreditation status on the FedRAMP Marketplace. Accreditation is granted by A2LA (American Association for Laboratory Accreditation) and must be current. Lapsed accreditation means assessments cannot be accepted.
Experience at Your Impact Level
Critical3PAOs vary significantly in experience across Low, Moderate, and High impact levels. High impact assessments require specialized expertise in national security controls. Ask specifically how many authorizations at your target level the 3PAO has completed in the past 24 months.
Industry Vertical Experience
HighHealthcare, financial services, and defense-adjacent systems have nuanced control implementations. 3PAOs with experience in your sector understand common implementation patterns and edge cases, reducing back-and-forth during assessment.
Assessment Team Composition
HighAsk who will actually perform the assessment. Some 3PAOs sell with senior personnel and deliver with junior staff. Request the CVs or bios of the specific assessment team, including their individual certification credentials.
Capacity and Scheduling
HighExperienced 3PAOs are heavily booked. Ask about current queue depth and estimated start date. A 3PAO quoting a very fast start may be understaffed or under-experienced. Expect 6-10 weeks scheduling lead time for quality 3PAOs.
SAR Quality and Agency Acceptance
MediumAsk for anonymized examples of Security Assessment Reports or agency references. SAR quality varies significantly. Poorly written SARs with ambiguous findings result in lengthy agency reviews and revision cycles.
Remediation Support
MediumSome 3PAOs offer remediation guidance as part of the assessment scope; others only identify findings. Clarify the boundary. A 3PAO cannot also serve as your compliance consultant for the same system (independence requirement).
ConMon Ongoing Relationship
MediumThe annual assessment subset during continuous monitoring is typically performed by the same 3PAO. Evaluate whether you want to maintain this relationship for 5+ years and factor relationship continuity into your selection.
Section C. Questions for 3PAO Candidates
Ten diligence questions
- 01.How many authorizations at this impact level has your team completed in the past 24 months?
- 02.Who specifically will lead the assessment, and can we review their credentials?
- 03.What is your current queue depth and estimated start date?
- 04.What is your process when you discover a High finding that was not anticipated?
- 05.Can you provide two or three agency references from recent authorization packages?
- 06.What do you include in your SAR - do you use pass/fail or graduated findings?
- 07.How do you handle disputed findings?
- 08.Do you offer continuous monitoring support, and what is that structured as?
- 09.Are there any conflict-of-interest constraints that would limit what other support you can provide?
- 10.How do you handle significant system changes that occur during the assessment period?
Note D / Independence Rule
3PAOs cannot also serve as your consultant
A 3PAO must maintain independence from the Cloud Service Provider it is assessing. The same firm cannot also serve as your FedRAMP compliance consultant, write your SSP, or implement controls for the same system. This is enforced by A2LA accreditation rules. You need separate vendors for consulting support and 3PAO assessment services. Some firms structure separate divisions; verify the personnel are fully isolated.
Section E. Named-Assessor Profiles
Six 3PAOs: positioning, pricing, fit
The accredited 3PAO market in 2026 is concentrated in roughly 30 firms. Below are six the site has detailed profiles for, ordered by typical Moderate-level price band.
| Assessor | Typical Moderate fee | Positioning | Best fit |
|---|---|---|---|
| GRSI | $300K - $500K | Boutique, defence-adjacent specialism | Smaller Moderate CSPs wanting hands-on senior staff |
| ControlCase | $350K - $550K | Multi-framework (FedRAMP + PCI + SOC2) | CSPs needing aligned audits across multiple frameworks |
| Kratos | $400K - $650K | DoD-heavy, IL5/6 experience | High-impact targets and IL5 transition planning |
| A-LIGN | $400K - $650K | Mid-market scale, common framework alignment | Moderate CSPs already in A-LIGN's SOC2/HITRUST orbit |
| Schellman | $500K - $750K | Enterprise-scale, multi-product CSPs | Larger CSPs with multiple FedRAMP boundaries |
| Coalfire | $550K - $850K | Largest accredited 3PAO, deepest agency-side relationships | Federally-strategic deployments where agency acceptance speed matters most |
Fees triangulated from CSP procurement disclosures and 3PAO published case studies. The full accredited list (~30 firms) is at FedRAMP Marketplace. The six above are profiled because they collectively cover >70% of recent Moderate authorizations.
Section F. Frequently Asked Questions
3PAO cost questions
How much does a 3PAO assessment cost?
As an indicative 2026 range, a 3PAO initial assessment costs $100K to $200K at FedRAMP Low, $350K to $650K at Moderate, and $700K to $1.2M or more at High. Annual continuous-monitoring assessments run roughly $30K to $60K at Low, $80K to $150K at Moderate, and $150K to $300K or more at High. 3PAOs do not publish rate cards, so treat these as planning bands, not quotes: the actual fee depends on system complexity, authorization boundary size, number of components, and impact level.
How much does a 3PAO cost at FedRAMP Moderate?
Moderate is the most competitive segment of the 3PAO market. An initial Moderate assessment is typically $350K to $650K, with wide variation driven by system complexity, the number of in-boundary components, and how much of the control set is inherited from an authorized IaaS such as AWS GovCloud or Azure Government. Annual continuous-monitoring assessment fees at Moderate are typically $80K to $150K.
Why don't 3PAOs publish fixed prices?
3PAOs set their own prices and do not publish rate cards, because no two FedRAMP engagements are directly comparable. Fee depends on impact level, boundary scope, component count, inheritance from underlying IaaS, and the maturity of the Cloud Service Provider's documentation. A tight, well-inherited Moderate boundary can cost less than a sprawling Low system. Always scope a specific quote against your own System Security Plan.
Can the same 3PAO also serve as my FedRAMP consultant?
No. A 3PAO must maintain independence from the Cloud Service Provider it assesses. The same firm cannot also write your System Security Plan, implement controls, or act as your compliance consultant for the same system. This independence is enforced by A2LA accreditation rules, so you need separate vendors for consulting support and 3PAO assessment. Some firms run isolated divisions; verify the personnel are fully separated.
Next step
Calculate your total FedRAMP budget
3PAO fees are one of six major cost buckets. Use the worksheet to estimate your complete authorization investment.