Section 6.05 - Reference Brief
DOC-REF: FRC-CMN-001
FedRAMP Continuous Monitoring Costs
FedRAMP authorization is not a one-time investment. Continuous monitoring obligations add $60,000 to $600,000+ per year depending on your impact level. Over five years, ConMon costs often exceed the initial authorization investment.
FedRAMP Low
$60,000 - $120,000
per year
5-Year ConMon total
$300,000 - $600,000
FedRAMP Moderate
$150,000 - $350,000
per year
5-Year ConMon total
$750,000 - $1,750,000
FedRAMP High
$300,000 - $600,000+
per year
5-Year ConMon total
$1,500,000 - $3,000,000+
Section A. Component Register
Cost components by activity
| Activity | Frequency | Low | Moderate | High |
|---|---|---|---|---|
| Monthly Vulnerability Scanning | Monthly | $12k - $24k/yr | $24k - $60k/yr | $48k - $120k/yr |
| Annual Penetration Testing | Annual | $15k - $30k/yr | $25k - $60k/yr | $40k - $80k/yr |
| 3PAO Annual Subset Assessment | Annual | $30k - $60k/yr | $80k - $150k/yr | $150k - $300k/yr |
| POA&M Management | Ongoing | $5k - $12k/yr | $15k - $40k/yr | $30k - $60k/yr |
| Incident Response Readiness | Ongoing | $5k - $10k/yr | $15k - $30k/yr | $25k - $50k/yr |
| Documentation Updates | Annual | $8k - $15k/yr | $20k - $40k/yr | $30k - $60k/yr |
| Significant Change Requests | As needed | $5k - $10k/yr | $10k - $30k/yr | $20k - $50k/yr |
Section B. 5-Year TCO
Total Cost of Ownership
A Moderate authorization is not a $1M investment. It is a $2.5M-$4M commitment over five years when ConMon is included.
| Period | Low | Moderate | High |
|---|---|---|---|
| Year 0 (Authorization) | $350k - $500k | $800k - $2M | $2.5M - $5M |
| Year 1 ConMon | $60k - $120k | $150k - $350k | $300k - $600k |
| Year 2 ConMon | $60k - $120k | $150k - $350k | $300k - $600k |
| Year 3 ConMon | $60k - $120k | $150k - $350k | $300k - $600k |
| Year 4 ConMon | $60k - $120k | $150k - $350k | $300k - $600k |
| Year 5 ConMon | $60k - $120k | $150k - $350k | $300k - $600k |
| 5-Year Total | $650k - $1.1M | $1.6M - $3.8M | $4M - $8M+ |
Section C. Compliance Risk
What happens if you stop ConMon
FedRAMP authorization is not a certificate that sits on a shelf. It is an active, ongoing relationship with the federal government. Failure to maintain ConMon obligations triggers an escalation cascade.
Missed ConMon deliverables
Warning from sponsoring agency. POA&M escalation. 30-day remediation window.
Continued non-compliance
Agency AO may suspend or downgrade the ATO. Access to agency systems may be restricted.
Authorization revocation
Removal from FedRAMP Marketplace. All leveraging agencies notified. Existing federal contracts at risk.
Re-authorization required
To regain FedRAMP authorization, you must go through the full authorization process again. No shortcut for reinstatement.
Section D. Looking Ahead
How FedRAMP 20x changes ConMon
FedRAMP 20x replaces the monthly manual reporting cycle with continuous automated compliance monitoring. Key Security Indicators (KSIs) provide real-time compliance data instead of monthly vulnerability scan reports.
Traditional ConMon
- Monthly vulnerability scan reports
- Annual 3PAO subset assessment
- Manual POA&M tracking and reporting
- Annual SSP update cycle
- Estimated: $150k-$350k/yr (Moderate)
20x ConMon (estimated)
- Continuous KSI reporting (automated)
- Automated evidence collection via OSCAL
- Real-time compliance dashboards
- Continuous documentation updates
- Estimated: $80k-$200k/yr (Moderate)
Next step
Factor ConMon into your total budget
The cost worksheet includes year-one ConMon and projects ongoing annual costs.