FedRAMP CR26 Customer Guide

What FedRAMP's Consolidated Rules for 2026 (CR26) mean for Game Warden customers, who is responsible for what, key dates, and your action checklist.

At a glance

FedRAMP's Consolidated Rules for 2026 (CR26) took effect July 4, 2026, and apply to Game Warden's Class D (High) certification. Most of the new work is Second Front's (2F). What you need to do depends on whether your application runs inside the Game Warden boundary or under your own FedRAMP certification.

  • Inside the Game Warden boundary: You're projected to fully inherit 182 of 205 CR26 requirements (89%). Your actions are mostly inputs we ask you for, such as logs, root cause details, and recovery objectives.
  • Your own boundary, built on Game Warden: You inherit the platform's technical controls, including most of the vulnerability rules: 24 of the 35 VDR and VER rules are fully inherited and 2 are shared. The certification rules are yours. VDR and VER take effect December 7, 2026. Your part is mainly reporting under your own certification and fixing vulnerabilities in your own code.

Game Warden's certification, and yours if you hold one, stays valid. FedRAMP keeps Rev5 certifications active until at least December 31, 2028.


Which model are you in?

The CI/CD pipeline, SOC, and platform controls are identical in both models. The difference is who holds the FedRAMP certification.

2F boundaryYour own boundary
Who holds the FedRAMP certificationSecond Front, for Game WardenYou, for your cloud service offering
Who meets the CR26 certification rulesSecond FrontYou, using Game Warden's inherited controls
Who reports incidents to FedRAMP and agenciesSecond FrontYou, unless your contract makes 2F your reporting agent
IdentityYour app uses the 2F IdP or federates through itYour choice of IdP

Not sure which model you're in? Check your Game Warden onboarding agreement or email us (see Getting help).


Key dates

The next deadline is December 7, 2026, for Vulnerability Detection and Response (VDR) and Vulnerability Evaluation and Reporting (VER). Most other rulesets follow during 2027. These are FedRAMP's Rev5 dates.

"Follow by" is when a certified service must be following the ruleset. After the grace period ends, a service that isn't following it loses its FedRAMP Certification. The last two columns show who meets each ruleset's rules, by number of rules.

RulesetFollow byGrace ends2F boundaryYour own boundary
Addressing FedRAMP Communication (AFC)Jan 5, 2026Jul 1, 20262F: 8You: 8
Secure Configuration Guide (SCG)Mar 1, 2026Jul 1, 20262F: 92F: 9
Marketplace Listing (MKT)Jul 4, 2026Jul 4, 20262F: 5You: 5
Vulnerability Detection and Response (VDR)Dec 7, 2026Mar 7, 20272F: 12 · Shared: 52F: 11 · Shared: 2 · You: 4
Vulnerability Evaluation and Reporting (VER)Dec 7, 2026Mar 7, 20272F: 182F: 13 · You: 5
Cryptographic Module Use (CMU)Jan 1, 2027Jun 1, 20272F: 1 · Shared: 2You: 3
FedRAMP Certification (FRC)Jan 1, 2027First assessment started after Jan 1, 20272F: 14 · Shared: 1 · N/A: 52F: 4 · Shared: 1 · You: 15
Incident Evaluation and Communication (IEC)Jan 1, 2027Jun 1, 20272F: 6You: 6
Independent Verification and Validation (IVV)Jan 1, 2027First assessment started after Jan 1, 20272F: 9You: 9
Minimum Assessment Scope (MAS)Jan 1, 2027First assessment started after Jan 1, 20272F: 2 · Shared: 1You: 3
Significant Change Notification (SCN)Jan 1, 2027Jun 1, 20272F: 15 · Shared: 12F: 14 · You: 2
Collaborative Continuous Monitoring (CCM)Apr 2, 2027Oct 1, 20272F: 172F: 3 · You: 14
Certification Package Overview (CPO)Jul 1, 2027First assessment started after Jul 1, 20272F: 4Shared: 3 · You: 1
Security Decision Record (SDR)Aug 1, 2027First assessment started after Aug 1, 20272F: 4Shared: 4
Certification Data Sharing (CDS)Aug 1, 2027Feb 1, 20282F: 20You: 20

FedRAMP's overall dates: new Rev5 applications must follow CR26 from January 1, 2027. FedRAMP stops accepting new Rev5 applications on June 11, 2027, and all grace periods end February 1, 2028. See FedRAMP's Important Deadlines.


What changes for you

CR26 changes how certification works, not the security of the platform you deploy to. These are the changes you'll notice:

Change2F boundaryYour own boundary
Word and Excel templates are replaced by machine-readable JSON (OSCAL optional), and the SSP becomes a Security Decision RecordSecond Front converts the Game Warden package. We'll ask for details about your app if needed.You convert your own package by the CPO and SDR dates. Second Front will supply Game Warden's inherited data.
POA&Ms are replaced by a list of Accepted WeaknessesSecond Front manages the list for Game Warden.You manage your own list.
FedRAMP no longer sets most review frequencies and thresholds; providers set their ownSecond Front sets them for Game Warden and will publish them to you.You set your own. Keep them consistent with the values Game Warden publishes for the controls you inherit.
Vulnerability response goes beyond monthly scans, with new remediation and reporting timelinesSecond Front detects, evaluates, and reports platform-wide. You fix vulnerabilities in your own code and images within the Game Warden remediation timelines.You meet VDR and VER by December 7, 2026, inheriting Game Warden's scanning and evaluation.
"Continuous monitoring" becomes Ongoing CertificationSecond Front handles it.You handle it for your service.

How much you inherit

Inside the Game Warden boundary, you're projected to fully inherit 182 of 205 requirements (89%), with none left entirely to you.

Projected requirements (205)2F boundaryYour own boundary
Fully inherited182 (88.8%)81 (39.5%)
Shared18 (8.8%)24 (11.7%)
Your responsibility0100 (48.8%)
Not applicable5 (2.4%)0

The 205 are the 159 CR26 rules plus the 46 Key Security Indicators (KSIs) FedRAMP requires for 20x Class C. FedRAMP hasn't published KSI requirements for Class D yet, so we track the Class C set.

Note

These figures are projections from our current CR26 responsibility mapping. Fully inherited means Second Front performs the activity, and you only supply inputs when asked. Shared means you perform part of it. Your customer responsibility matrix will show each requirement.

Key Security Indicators

Inside the Game Warden boundary, 38 of the 46 KSIs are projected to be fully inherited. The other 8 are shared, and most of them cover access and data inside your application, which only you control.

Shared KSI (2F boundary)Second Front handlesYou handle
KSI-IAM-AAM Automating Account ManagementAccount lifecycle through the 2F IdP, including provisioning, inactivity disablement, and revocationRoles, groups, and privileges inside your app
KSI-IAM-ELP Ensuring Least PrivilegeLeast privilege for platform, infrastructure, and pipeline accessLeast-privilege roles and permissions inside your app
KSI-IAM-JIT Authorizing Just-in-TimeJust-in-time authorization for privileged platform accessJust-in-time and role-based access inside your app
KSI-RPL-ARP Aligning Recovery PlanThe platform recovery planYour app's recovery plan
KSI-SCR-MIT Mitigating Supply Chain RiskPipeline scanning, SBOMs, and policy gates on images and dependenciesChoosing your dependencies and vendors
KSI-PIY-RSD Reviewing Security in the SDLCSecure-by-design checks enforced in the pipelineSecurity in your development practices before code reaches the pipeline
KSI-SVC-RUD Removing Unwanted DataRemoving data from platform storage and backups on agency requestRemoving data held inside your app
KSI-CED-RAT Reviewing All TrainingTraining for Second Front personnelTraining for your developers and staff

If you run your own boundary, the technical KSIs are inherited the same way, because the pipeline and SOC are identical. KSIs about your own security program, such as executive support, security investments, your vulnerability disclosure program, and staff training, are yours. So are most identity KSIs, unless your app uses the 2F IdP.

FedRAMP's full list is in its Key Security Indicators reference.


Your action checklist

If you're in the 2F boundary

  • Make sure your app authenticates through the 2F IdP or federates through it with phishing-resistant MFA.
  • Forward your application security and access logs to the 2F SOC.
  • Provide your app's RTO and RPO, and review them when the platform prompts you.
  • Provide application-level root cause analysis to the 2F SOC when asked after an incident.
  • Fix vulnerabilities in your own code and images within the Game Warden remediation timelines.
  • Tell us about significant changes to your app before you deploy them.
  • Keep roles, least privilege, and just-in-time access inside your app current.
  • Maintain your app's recovery plan, and train your developers and staff.

If you run your own boundary

  • Meet VDR and VER by Dec 7, 2026, inheriting Game Warden's scanning and evaluation.
  • Follow CMU, FRC, IEC, IVV, MAS, and SCN by Jan 1, 2027.
  • Set your own review frequencies and thresholds, consistent with the values Game Warden publishes.
  • Follow CCM by Apr 2, 2027.
  • Convert your package to the Certification Package Overview by Jul 1, 2027.
  • Publish your Security Decision Record and follow CDS by Aug 1, 2027.
  • Request Game Warden's inherited data for your package from your 2F contact.

FAQ

Do I need to change my plans, policies, or other documentation?

In the 2F boundary, Second Front handles the package changes and will tell you if we need anything from you. If you run your own boundary, you'll move your package from the legacy templates to FedRAMP's machine-readable formats by the CPO and SDR dates.

Will my responsibilities change?

In the 2F boundary, you're projected to fully inherit 89% of requirements and none fall entirely on you. Your main new inputs are recovery objectives, root cause details after incidents, and using the 2F IdP.

What happens with FedRAMP 20x?

FedRAMP 20x has no Class D (High) path yet. FedRAMP expects to pilot it in late 2026 and offer it formally in early 2027. We'll publish our transition plan once Class D requirements are released.

Can I keep using my own identity provider?

Yes, by federating it through the 2F IdP, which enforces phishing-resistant MFA for all apps in the 2F boundary.

When will I get the updated responsibility matrix?

We'll publish the final CR26 customer responsibility matrix here when it's ready.


Getting help

Questions about CR26 or your responsibilities? Email fedramp@secondfront.com or contact your 2F Mission Success Manager.

Reviewed by Melanie Huffman, Director, FedRAMP Program. Dates reflect FedRAMP's Consolidated Rules for 2026 as published in October 2026 and may change.

November 6, 2026
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