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tags:
  - Independent Assessors
  - Guidance
picto:
  source: person
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<span class="picto">:lucide-person-standing:{ .person title="This content was written by a human just for this page." }</span>

# Updating to 2026 Rules

FedRAMP Recognized independent assessment services are expected to be familiar with all of the relevant
FedRAMP Practices that apply to cloud service providers as well as those that apply to assessors. To
get the most out of preparing to update to the Consolidated Rules for 2026, please start by reviewing
all of the content and materials produced for cloud service providers:

- [Updating to 2026 Rules (for Cloud Service Providers)](../../providers/updating/index.md){ data-preview }

## 3PAO -> Independent Assessment Service

The [original FedRAMP memorandum from 2011](../../authority/rescinded-2011-fedramp-memo.md) directed
FedRAMP to establish a _"conformity assessment program capable of producing consistent independent,
third-party assessments of security controls implemented by CSPs.."_ and named the organizations
that would perform such assessments as third-party assessment organizations (3PAOs).

This approach was changed significantly when FedRAMP was rescinded and replaced by
[M-24-15](../../authority/m-24-15/index.md) after the formal establishment of FedRAMP in the
[FedRAMP Authorization Act](../../authority/law/index.md):

- The law no longer expected FedRAMP to rely on third-party assessment by default; instead it directed FedRAMP itself to
  do so.
- The law does, however, allow FedRAMP to _"use an independent assessment service to analyze, validate, and attest to the quality and compliance of security assessment materials provided by cloud service providers during the course of a determination..."_
- M-24-15 makes only a single mention of third-party assessors while describing the history of FedRAMP.
- M-24-15 explicitly requires FedRAMP to assess the security posture of cloud services to grant a Program Certification, but does not disallow the use of independent assessment services to analyze, validate, and attest to materials on FedRAMP's behalf.

This is why the terminology and expectations for independent assessment services have changed.

