FedRAMP is at the center of the federal mandate on cloud technology, offering a standardized approach for assessing, authorizing, and continuously monitoring these services across agencies. But even with a mature framework, FedRAMP processes can be time-consuming and document-heavy.

This is where the Open Security Controls Assessment Language (OSCAL) comes in. This transformative initiative introduces machine-readable reporting for security documentation, enabling the automation of reports. For cloud service providers, Third-Party Assessment Organizations (3PAOs), and federal stakeholders, adopting OSCAL is becoming essential for staying ahead in the compliance lifecycle.

What is OSCAL?

OSCAL is a set of standardized data formats (specifically XML, JSON, and YAML) developed by NIST to represent control catalogs, control baselines, system security plans (SSPs), assessment plans and results, and plans of action and milestones (POA&Ms). By transforming documents into structured data, OSCAL facilitates automation, validation, transformation, and integration across various platforms and tools.

OSCAL aims to modernize the Risk Management Framework (RMF) process by enabling consistency across documentation, promoting interoperability between tools, facilitating machine-based validation, and integrating it into DevSecOps pipelines.

FedRAMP documentation requirements are extensive, encompassing the SSP, Security Assessment Plan (SAP), Security Assessment Report (SAR), and POA&M, among others. These documents are traditionally created and reviewed in Word or Excel formats, which are prone to inconsistencies and manual errors. They are also time-intensive to prepare and validate.

With OSCAL, these documents become structured data models that can be auto-generated from templates, programmatically validated for completeness, transformed for presentation or reporting, and version-controlled with diff-tracking capabilities. This automation reduces the review burden on both CSPs and 3PAOs, and speeds up the assessment process.

Automating the System Security Plan

The SSP is the cornerstone of any FedRAMP package, describing how a system implements required controls. In OSCAL format, the SSP becomes a structured data model that includes:

• Metadata: Version information, publication dates, and authorship details.
• System Characteristics: System boundary definitions, architecture diagrams, and impact level classifications.
• Implemented Controls: Detailed control parameters and implementation specifications
• Control Origination and Responsibility: Clear delineation of CSP, system, and hybrid control responsibilities.

By encoding this information in a machine-readable format, CSPs can ensure the accuracy of control documentation while automating updates and conducting pre-submission validation.

Streamlining the Security Assessment Report

The SAR details the findings from the 3PAO’s assessment, documenting which controls are effectively implemented and which are not. Using OSCAL, 3PAOs can structure their assessment data to include:

• Control Mapping: Direct linkage of each control to its specific test method (test, interview, or examination).
• Evidence References: Structured documentation of evidence and assessment outcomes.
• Standardized Results: Assessment findings that integrate seamlessly into FedRAMP’s risk review process.

This structured approach ensures traceability, enables delta comparisons for reassessments, and supports more informed and faster risk decisions by reviewers.

Digitizing the Plan of Action and Milestones

The POA&M lists all known remaining deficiencies, mitigation plans, and target completion dates. With OSCAL, each POA&M item becomes a structured data object, enabling:

• Real-Time Updates: Direct integration with ticketing systems and GRC tools for live status tracking.
• Automated Linking: Auto-connection to failed control references documented in the SAR.
• Intelligent Reporting: Automated prioritization and reporting based on severity levels and risk exposure.

The result is a living risk register that can be easily filtered, sorted, and monitored by all stakeholders.

Enabling Continuous Authorization and DevSecOps

As agencies look to transition to Continuous Authorization to Operate, real-time compliance becomes increasingly critical. OSCAL provides the backbone for integrating compliance data into CI/CD pipelines, where configuration changes trigger control reassessments. DevSecOps tools can auto-generate updated SSP sections, and security teams can maintain ongoing visibility into POA&M status.

This shift transforms compliance from a static milestone to a dynamic, integrated process.

FedRAMP OSCAL Support and Resources

Adopting OSCAL requires initial investment in tooling, training, and workflow redesign. Common challenges include tooling compatibility across XML, JSON, or YAML formats, integration with existing GRC platforms, and alignment with 3PAO assessment workflows.

However, the benefits outweigh the startup effort, especially for CSPs that manage multiple authorizations or operate at scale.

FedRAMP has released OSCAL-enabled versions of core templates and offers validation tools to help organizations ensure compliance with schema requirements. Key resources include the FedRAMP OSCAL System Security Plan Template, OSCAL validation scripts and CLI tools, as well as mapping guides that connect FedRAMP controls to OSCAL data fields.

CSPs and 3PAOs are strongly encouraged to coordinate early with FedRAMP to align their OSCAL-based submissions and workflows.

Automate Your FedRAMP Assessments with Continuum GRC

For organizations looking to stay competitive in the federal cloud market, the time to invest in OSCAL is now. Not only does it enhance operational efficiency, but it also signals a commitment to security maturity and innovation that resonates with federal customers and regulators alike.

Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance).

• FedRAMP
• StateRAMP
• NIST 800-53
• FARS NIST 800-171 & 172
• CMMC
• SOC 1 & SOC 2
• HIPAA
• PCI DSS 4.0
• IRS 1075 & 4812
• COSO SOX
• ISO 27001 + other ISO standards
• NIAP Common Criteria
• And dozens more!

We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cybersecurity® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect its systems and ensure compliance.