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Penetration Test Guidance Public Comment Period

March 4 | 2024

Penetration Test Guidance Public Comment Period

FedRAMP is seeking feedback on the draft FedRAMP Penetration Test Guidance. The original guidance provides requirements for organizations planning to conduct a FedRAMP penetration test to identify weaknesses in their IT system, as well as the associated attack vectors and overall reporting requirements.

The FedRAMP Rev. 5 High, Moderate, Low, and Li-SaaS baselines include an annual requirement for penetration testing. For FedRAMP Low and Li-SaaS baselines, an independent assessor is not required and scope can be limited to public facing applications in alignment with OMB Memorandum M-22-09.

The updated guidance explains the requirements for organizations executing FedRAMP penetration tests and reporting testing results. Third Party Assessment Organizations (3PAOs) must follow the requirements for testing implementation. Cloud Service Providers can use the guidance to understand the scope of, and their role in the 3PAO testing. The guidance has been updated to include the Red Team Testing Requirements. More information can be found in our most recent blog post highlighting the additional Rev. 5 documents that were released, which were adopted in FedRAMP baselines. FedRAMP does not provide a Penetration Testing and Reporting template.

The existing FedRAMP Penetration Test Guidance vectors are based on threat and attack models listed in the updated guidance. These have remained standard. However, based on the current threat environment, FedRAMP understands additional attack vectors might be defined for consideration, e.g., vectors applicable to Data Loss Prevention subsystems. If a stakeholder feels it reasonable to include additional attack vectors for consideration, the additional threat and attack models should also be included, as applicable. At a minimum, FedRAMP requires that all mandatory attack vectors outlined in the FedRAMP Penetration Test Guidance are covered in every 3PAO Penetration Test and Report.

Additionally, several other requirements were updated to provide clarity and ensure that requirements were identified as mandatory instead of optional. Outlined below are the most notable updates:

  • NIST SP 800-53 Revision 5 update - Security Control CA-8(2) Security Assessment and Authorization, Penetration Testing, Red Team Exercises for all FedRAMP High and Moderate criticality systems added as Appendix E: Red Team Exercises.
  • Language clarifications to ensure that the mandatory requirements are better understood.
  • Detailed explanation of the Email Phish Campaign requirements to most effectively conduct the campaign. Updates were made for landing page requirements for CSP personnel who are victims of the campaign.
  • Addition of references to the MITRE ATT&CK(R) Matrix for Enterprise and the NIST Red Team Definition.

Note that the CA-8(2) Red Team Testing Requirements outlined in the Penetration Test Guidance address the NIST/FedRAMP testing requirements, and are not the same as the ‘intensive, expert-led “red team”’ assessments referred to in the Office of Management and Budget draft memo, Modernizing the Federal Risk and Authorization Management Program (FedRAMP) (which was discussed previously on the FedRAMP blog).

If you have comments, edits, or feedback on the draft updated Penetration Test Guidance, submit them via the Public Comments_Draft Penetration Test Guidance form by April 24, 2024. Please be sure to include the specific draft section to which your question or comment refers. To read comments that have already been submitted, you may view the Public Comments Draft Penetration Test Guidance read-only version.

As always, we appreciate your input. If you have any questions please email

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