FedRAMP Low, Moderate and High Baselines (Rev 5): Control Counts and Differences

FedRAMP impact levels determine how many NIST SP 800-53 controls you implement and assess. Per the official FedRAMP Rev. 5 Transition Overview, Rev 5 baselines include:

Low 156 · Moderate 323 · High 410 controls.

Related: FedRAMP 20x · Checklist · Hub.

Official Rev 5 counts: Low 156 / Moderate 323 / High 410. Tailored / LI-SaaS presentations commonly cite 66 controls tested and 90 attested. Confirm your exact package type with FedRAMP and your 3PAO.

Low (156)

Appropriate when loss of confidentiality, integrity, or availability would have limited adverse effect. Still requires a complete SSP, assessment, and ConMon — not a paperwork waiver.

Moderate (323)

The most common commercial SaaS target for federal business. Expect deeper identity, encryption, logging, and contingency requirements than Low.

High (410)

For systems where loss would have severe or catastrophic adverse effect. Higher assurance, deeper testing, and stricter operational expectations.

Tailored / LI-SaaS

FedRAMP Tailored for LI-SaaS reduces the assessed set relative to full baselines. Industry presentations of the same programme materials commonly reference 66 controls tested and 90 attested. Validate applicability before choosing Tailored over Low.

20x Class Mapping (Legacy → Class)

Ready — Class A
Low / Li-SaaS — Class B
Moderate — Class C
High — Class D (later)

New Rev 5 certifications stop being accepted on June 11, 2027 — plan baseline choice against that transition.

How CyberSilo Helps

Evidence workflows for SSP, POA&M, and control status via Compliance Standards Automation
ThreatHawk SIEM for AU-family logging, ConMon telemetry, and investigation evidence
Advisory scoping for readiness, baseline selection, and agency-path planning — contact CyberSilo

Choose the Right Baseline First

Mis-scoping Low vs Moderate wastes months. Align data types, agency demand, and engineering reality.

Talk to CyberSilo FedRAMP Hub

Frequently Asked Questions

Why do some sites still say 325 Moderate controls?

Older secondary summaries drift. Use the official Rev. 5 Transition Overview figures: Low 156, Moderate 323, High 410.

Is LI-SaaS automatic for all SaaS?

No. Tailored applicability has criteria. Confirm with FedRAMP guidance and your assessor.

Do control counts vanish under 20x?

20x emphasizes KSIs and classes. Rev 5 counts remain the planning baseline through the published transition window.

20x · SSP · Timeline · Hub