FedRAMP ConMon Deliverables · Monthly & Annual Checklist
by PJ · solo operator · sideguysolutions.com · Cardiff · 858-461-8054Shopping for the platform instead? See FedRAMP ConMon software compared.
FedRAMP ConMon deliverables · monthly, annual, event-driven.
Every item below is sourced to fedramp.gov and linked. Nothing here is a vendor claim.
Monthly deliverables (Rev5 ConMon process)
- Updated POA&M and inventory. "Each month, the CSP uploads an up-to-date POA&M and inventory, along with raw vulnerability scan files (when required by agreements with agency customers) and reports to the secure repository." (per FedRAMP ConMon Playbook, legacy Rev5 docs on fedramp.gov, Overview)
- Vulnerability scan results. Operating systems, web applications, and databases are scanned monthly; scan output must show all findings rated low risk or higher in a structured, machine-readable format (such as XML, CSV, or JSON), with NVD CVE references where available and CVSSv3 base scores. (per FedRAMP ConMon Playbook, legacy Rev5 docs on fedramp.gov, Vulnerability Scanning)
- Summary report, deviation requests (DRs), significant change requests (SCRs). FedRAMP lists the monthly set as "summary report, vulnerability scan files, updated POA&M and Inventory, DRs, SCRs," recommends uploading them on the same day each month, and holding the recurring ConMon meeting a week later. (per FedRAMP ConMon Playbook, legacy Rev5 docs on fedramp.gov, Collaborative ConMon)
Annual deliverables
- Annual assessment with an independent assessor. The CSP and a FedRAMP-recognized 3PAO assess a FedRAMP-selected list of core controls, controls the CSP selects because of recent system changes, validation of closed findings and vendor dependencies, verification of controls marked N/A, and any controls not assessed within three years. (per FedRAMP ConMon Playbook, legacy Rev5 docs on fedramp.gov, Annual Assessment)
- SAP, SAR, and an updated POA&M. The assessment produces a Security Assessment Plan, a Security Assessment Report (with appendices including a Risk Exposure Table), and a POA&M update for residual risks identified in the SAR. (same source)
Event-driven deliverables
- Significant change requests. The CSP documents an SCR for transformative or adaptive changes; the SCR and a Security Assessment Plan go to the authorizing official for review and approval, and an assessor tests the change and produces a SAR (a smaller-scope adaptive change may use an assessor attestation letter if the AO agrees). (per FedRAMP ConMon Playbook, legacy Rev5 docs on fedramp.gov, Significant Changes)
- Incident reports. Impacted customers, CISA, FedRAMP, and agency points of contact (including authorizing officials) are notified within one hour of the incident being identified by the CSP's top-level CSIRT, SOC, or IT department. (per FedRAMP ConMon Playbook, legacy Rev5 docs on fedramp.gov, Incident Communication)
What the Consolidated Rules for 2026 change
For Rev5 providers, FedRAMP's CA-7 control guidance now points to the Collaborative Continuous Monitoring, Significant Change Notification, Vulnerability Detection and Response, and Vulnerability Evaluation and Reporting rules (per FedRAMP Consolidated Rules for 2026, Rev5 CA controls). The deliverables that shift:
- Quarterly Ongoing Certification Report. Providers must supply one to all necessary parties every 3 months, covering changes to certification data, planned changes, accepted vulnerabilities, transformative changes, updated recommendations, the list of agencies using the product, and FedRAMP reportable incidents (or an attestation of none). Class C and D providers must also host a synchronous Quarterly Review; Class B should; Class A may. (per FedRAMP Consolidated Rules for 2026, CCM-OCR-AVL, CCM-QTR-MTG)
- Monthly vulnerability reporting stays. Providers must report vulnerability detection and response activity to all necessary parties in a consistent, human-readable format at least monthly. (per FedRAMP Consolidated Rules for 2026, VER-TFR-MHR)
- Annual independent assessment stays. Class B, C, and D providers must complete an independent verification and validation assessment with a FedRAMP Recognized independent assessment service or FedRAMP at least once per year, and every applicable Rev5 control must be covered at least every 3 years. (per FedRAMP Consolidated Rules for 2026, IVV-CSO-FIA, IVV-CSF-MCA)
- Change requests become notifications. Routine recurring changes need no formal notification; adaptive changes are reported within 10 business days after finishing; transformative changes need initial plans at least 30 business days and final plans at least 10 business days before starting. (per FedRAMP Consolidated Rules for 2026, Significant Change Notification)
- Incident reporting timelines depend on class. Providers communicate incidents to FedRAMP, agency customers, and all necessary parties on timeframes set by certification class and incident impact rating. (per FedRAMP Consolidated Rules for 2026, Incident Evaluation and Communication)
FedRAMP 20x publishes the same Collaborative Continuous Monitoring ruleset (quarterly Ongoing Certification Reports and Quarterly Reviews) (per FedRAMP Consolidated Rules for 2026, 20x CCM).
Tools that produce these deliverables · what the software must cover.
The platforms below are the tools that produce the deliverables above. The existing ConMon comparison defines the core work as monthly POA&M submission, vulnerability-scan ingestion, remediation tracking, Change Requests for significant authorization-boundary changes, and evidence freshness for the annual 3PAO assessment.
The short version: ConMon is not a dashboard you glance at once a quarter. It is the monthly operating system for POA&M, scanning, remediation, change management, and annual assessment readiness.
Calling Matrix · who fits which route.
| Buyer situation | Best route from the source page | Why |
|---|---|---|
| SOC 2 team already in Vanta | Vanta | It is easiest if you already run SOC 2 on Vanta. |
| Automated POA&M lifecycle is the core pain | Drata | The source page names Drata as the forced pick for the most automated POA&M lifecycle. |
| Multi-framework GRC and change workflows matter | Hyperproof | Deepest change-management workflows and multi-framework fit in the source matrix. |
| Public-sector-native FedRAMP scope | Telos Xacta | The source page calls Telos public-sector-native. |
| ConMon as a managed service | Anitian or StackArmor | The source page says these vendors operate ConMon as a service. |
Cost and failure points · what drives them.
Post-ATO ConMon cost depends on scope: platform license, 3PAO annual assessment, internal engineering time and remediation.
Missed monthly POA&M submissions escalate through agency follow-up and corrective action, and a chronic pattern puts the authorization at risk. The practical priority is keeping the monthly POA&M and remediation loop boring and on time.
FAQ · ConMon deliverables and tools
What are the monthly FedRAMP ConMon deliverables?
Under the Rev5 ConMon process, FedRAMP lists the monthly deliverables as a summary report, vulnerability scan files, an updated POA&M and inventory, and any deviation requests (DRs) and significant change requests (SCRs). Operating systems, web applications, and databases are scanned monthly. Source: FedRAMP ConMon Playbook (legacy Rev5 docs on fedramp.gov).
What is the annual FedRAMP ConMon deliverable?
An annual assessment with a FedRAMP-recognized 3PAO covering FedRAMP-selected core controls, controls affected by recent changes, validation of closed findings, and controls not assessed within three years. It produces a Security Assessment Plan, a Security Assessment Report, and an updated POA&M. The Consolidated Rules for 2026 keep an at-least-annual independent assessment for Class B, C, and D providers.
When are significant change requests and incident reports submitted?
They are event-driven. Under the legacy Rev5 process, an SCR and Security Assessment Plan go to the authorizing official for approval before the change, and incidents are reported within one hour of identification to impacted customers, CISA, FedRAMP, and agency points of contact. Under the Consolidated Rules for 2026, change notification timing depends on change type and incident timing depends on certification class and impact rating.
Did FedRAMP 20x or the 2026 rules change ConMon deliverables?
Yes. fedramp.gov marks the Rev5 ConMon playbook as legacy during the transition to the Consolidated Rules for 2026, which take mandatory effect January 1, 2027. The new Collaborative Continuous Monitoring rules (published for both Rev5 and 20x) require a quarterly Ongoing Certification Report, while vulnerability reporting stays at least monthly.
What is FedRAMP ConMon software?
FedRAMP ConMon software is tooling that keeps an authorization alive after ATO: monthly POA&M, vulnerability-scan ingestion, remediation tracking, Change Requests for boundary changes, and evidence freshness for the annual 3PAO assessment.
Which FedRAMP ConMon platform should I pick?
From the source Calling Matrix: Drata if automated POA&M is the core constraint, Vanta if you already run SOC 2 there, Hyperproof for deeper change-management workflows, Telos for public-sector-native scope, and Anitian or StackArmor if you want ConMon operated as a service.
How much does FedRAMP ConMon cost after ATO?
Cost depends on scope: the ConMon platform, the annual 3PAO assessment, internal compliance and security engineering time, monthly scanning, and remediation. Get quotes from your platform vendor and 3PAO; we don't publish a range we can't source.
Can ConMon be outsourced entirely?
Yes. Anitian, StackArmor, and some 3PAO-adjacent firms offer FedRAMP-as-a-managed-service post-ATO while the customer keeps ownership of the authorization.
What happens if monthly POA&M is missed?
Your authorizing official and agency see it first. Repeated misses escalate through agency follow-up and corrective action, and chronic problems put the authorization at risk.
What should a small engineering team choose?
If the team is too small to absorb a dedicated FedRAMP function, the source page says operated-for-you ConMon from Anitian or StackArmor can remove internal staffing burden at higher annual cost.
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