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Engineering23 April 2026·3 min read

What it takes to get FedRAMP authorized: Lessons from companies that did it

A design is a set of bets.

Paycux engineering

A design is a set of bets. Writing down which bets you are making — and what would have to be true for them to be wrong — costs an afternoon and saves a rewrite.

This piece walks through how we think about it at Paycux, what we have changed our minds about, and where the sharp edges are.

FedRAMP 101

FedRAMP 101 is where this gets concrete. Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument. A p50 that looks fine while the p99 is unusable is a reporting failure, not a performance one.

Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument. A p50 that looks fine while the p99 is unusable is a reporting failure, not a performance one.

What FedRAMP actually demands

Consider what fedramp actually demands. Make the boundary explicit. When one part of the system can only talk to another through a named interface, you can change either side without a meeting; when it cannot, every change becomes a negotiation.

Idempotency is not a nice-to-have in any system with retries. Key on an identifier the caller supplies, store the outcome, and return the same answer to the same key rather than doing the work twice.

  • Name the boundary before you cross it
  • Measure what users feel, not what is easy to instrument
  • Make every retried operation idempotent
  • Write down the assumption that would invalidate the design

Wiz: Risk first, not checklist first

Wiz: Risk first, not checklist first deserves its own treatment. Make the boundary explicit. When one part of the system can only talk to another through a named interface, you can change either side without a meeting; when it cannot, every change becomes a negotiation.

Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument. A p50 that looks fine while the p99 is unusable is a reporting failure, not a performance one.

GitLab: The agency-sponsored Moderate path

Consider gitlab: the agency-sponsored moderate path. Idempotency is not a nice-to-have in any system with retries. Key on an identifier the caller supplies, store the outcome, and return the same answer to the same key rather than doing the work twice.

Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument. A p50 that looks fine while the p99 is unusable is a reporting failure, not a performance one.

Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument.

Databricks: Stacking authorizations for the federal market

That brings us to databricks: stacking authorizations for the federal market. Make the boundary explicit. When one part of the system can only talk to another through a named interface, you can change either side without a meeting; when it cannot, every change becomes a negotiation.

Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument. A p50 that looks fine while the p99 is unusable is a reporting failure, not a performance one.

Beyond Identity and the startup reality

That brings us to beyond identity and the startup reality. Make the boundary explicit. When one part of the system can only talk to another through a named interface, you can change either side without a meeting; when it cannot, every change becomes a negotiation.

Make the boundary explicit. When one part of the system can only talk to another through a named interface, you can change either side without a meeting; when it cannot, every change becomes a negotiation.

What FedRAMP 20x changed, and did not change

What FedRAMP 20x changed, and did not change deserves its own treatment. Measure before you optimise, then measure the thing users feel rather than the thing that is easy to instrument. A p50 that looks fine while the p99 is unusable is a reporting failure, not a performance one.

Make the boundary explicit. When one part of the system can only talk to another through a named interface, you can change either side without a meeting; when it cannot, every change becomes a negotiation.

Where this leaves us

The pattern repeats across every system we have looked at: the hard part is not the mechanism, it is keeping the mechanism honest as the surrounding assumptions change.

If you are working through the same problem and want to compare notes, the docs cover the mechanics and the console shows the behaviour on your own data.

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