Earlier this year, FedRAMP RFC-0012 signaled a coming shift in how cloud service providers (CSPs) working with the U.S. federal government are expected to handle vulnerabilities. 

It outlined plans to move FedRAMP away from simple CVSS-score thresholds and toward continuous, context-aware, exploitability-driven, and automation-first vulnerability management. 

After public feedback, the findings from RFC-0012 were taken into consideration, and the draft shared was modified and released as the brand new Vulnerability Detection and Response (VDR) Standard, which is now in effect. 

For most CSPs, the practical takeaway is clear: you need to find and fix credibly exploitable vulnerabilities much faster, with much better evidence and automation. Seal Security was built to address this exact issue.

Why Does The New FedRAMP VDR Standard Matter for CSPs?

The new FedRAMP VDR standard calls on any cloud service providers (CSPs) that are looking to work with the US Federal Government to go beyond base CVSS scores and integrate deeper contextual signals into their vulnerability response programs. 

The new standard asks CSPs to:

• Go beyond base CVSS scores, incorporating context such as reachability, exploitability, impact, and mitigations.
• Put special emphasis on internet-reachable resources, which are explicitly prioritized.
• Use automated systems to detect, evaluate, mitigate, and remediate vulnerabilities continuously.
• Produce detailed vulnerability reports for FedRAMP, CISA, and agency customers.
• Align vulnerability timelines with specific, documented targets.

For any CSP targeting FedRAMP authorization or maintaining an Authorization to Operate (ATO), this means your current vulnerability program must be able to prove continuous detection, context-rich prioritization, and fast, auditable remediation.

How Are Vulnerabilities Categorized in The FedRAMP VDR?

In order to support the new FedRAMP introduced timelines based on reachability, exploitability, and impact, outlined in FRR-VDR-TF, the following category system was introduced.

First, providers must evaluate detected vulnerabilities, considering the context of the cloud service offering, to estimate the potential adverse impact of exploitation on government customers, and assign one of the 5 following potential adverse impact ratings:

• N1: Exploitation could be expected to have negligible adverse effects on one or more agencies that use the cloud service offering.
• N2: Exploitation could be expected to have limited adverse effects on one or more agencies that use the cloud service offering.
• N3: Exploitation could be expected to have a serious adverse effect on one agency that uses the cloud service offering.
• N4: Exploitation could be expected to have a catastrophic adverse effect on one agency that uses the cloud service offering OR a serious adverse effect on more than one federal agency that uses the cloud service offering.
• N5: Exploitation could be expected to have a catastrophic adverse effect on more than one agency that uses the cloud service offering.

Once a vulnerability’s potential impact is assigned one of these categorizations, its reachability and exploitability are assessed.

• If a vulnerability is likely exploitable and internet reachable, it is an LEV + IRV.
• If a vulnerability is likely exploitable but not internet reachable, it is an LEV + NIRV.
• If a vulnerability is not likely exploitable, it is a NLEV.

What are FedRAMP’s VDR Standard Response Timelines?

Providers must mitigate or remediate vulnerabilities within the guidelines created for their respective category in the new VDR standards.

For vulnerabilities in high authorization systems, the guidelines are the most strict to reflect the importance of their remediation.

• All vulnerabilities in these systems must be evaluated within 2 days of detection
• All LEV + IRVs rated N4 or N5 must be treated as an incident until partially mitigated to N3 or below, and all LEV + NIRVs rated N5 must be until to N4 or below.
• Providers SHOULD partially mitigate vulnerabilities to a lower potential adverse impact within the maximum time-frames from evaluation shown below, factoring for the current potential adverse impact, internet reachability, and likely exploitability:
  
  • N5: .5 days for LEV + IRV, 1 day for LEV + NIRV, 8 days for NLEV
  • N4: 2 days for LEV + IRV, 8 day for LEV + NIRV, 32 days for NLEV
  • N3: 8 days for LEV + IRV, 16 day for LEV + NIRV, 64 days for NLEV
  • N2: 24 days for LEV + IRV, 96 day for LEV + NIRV, 192 days for NLEV
    

For vulnerabilities in moderate authorization systems, the guidelines are slightly more lenient.

• All vulnerabilities in these systems must be evaluated within 5 days of detection
• All LEV + IRVs rated N4 or N5 must be treated as an incident until partially mitigated to N3 or below.
• Providers SHOULD partially mitigate vulnerabilities to a lower potential adverse impact within the maximum time-frames from evaluation shown below, factoring for the current potential adverse impact, internet reachability, and likely exploitability:
  
  • N5: 2 days for LEV + IRV, 4 days for LEV + NIRV, 16 days for NLEV
  • N4: 4 days for LEV + IRV, 8 days for LEV + NIRV, 64 days for NLEV
  • N3: 16 days for LEV + IRV, 32 days for LEV + NIRV, 128 days for NLEV
  • N2: 48 days for LEV + IRV, 128 days for LEV + NIRV, 192 days for NLEV

Lastly, for vulnerabilities in low authorization systems, the guidelines are the most forgiving.

• All vulnerabilities in these systems must be evaluated within 5 days of detection
• There are no categorizations of vulnerability that are treated as incidents.
• Providers SHOULD partially mitigate vulnerabilities to a lower potential adverse impact within the maximum time-frames from evaluation shown below, factoring for the current potential adverse impact, internet reachability, and likely exploitability:
  
  • N5: 4 days for LEV + IRV, 8 days for LEV + NIRV, 32 days for NLEV
  • N4: 8 days for LEV + IRV, 32 days for LEV + NIRV, 64 days for NLEV
  • N3: 32 days for LEV + IRV, 64 days for LEV + NIRV, 192 days for NLEV
  • N2: 96 days for LEV + IRV, 160 days for LEV + NIRV, 192 days for NLEV

While FedRAMP has labeled these timeframes with should, this doesn’t mean they are “nice to have” targets. They become the baseline expectation for how quickly you can respond, with evidence. For many organizations, traditional “upgrade your way out of it” remediation makes these timelines almost impossible to hit at scale.

Additionally, providers are encouraged to go above and beyond these thresholds, as performance will be scored against others in the FedRAMP marketplace, which could impact your bottom line.

How Seal Security Helps You Stay Aligned with FedRAMP’s VDR Standard

Staying VDR compliant requires fast and effective remediation, even in situations where it may be difficult. Seal Security was built for navigating these difficult environments. 

Our production-ready patches eliminate vulnerabilities without forcing dependency or OS upgrades, helping security, compliance, and dev teams fix what matters, in just one click. Here’s how we give you the tools to stay in alignment with the regulations introduced in RFC-0012:

Patch-in-Place for Direct and Transitive Vulnerabilities

Without Seal, remediating a CVE could involve a tedious upgrade process or fragile manual backporting work to create your own fix. These processes can take countless hours, if not weeks, and can lead to backlogs that grow seemingly forever.

With Seal, remediating a CVE can take just a few seconds. We take on the work to patch the version you're running, backporting the upstream fix and verifying it with upstream tests. Once this is done, it’s available on our platform, where you can deploy the updated, Sealed version in one click.

This means faster remediation with zero disruption, even when the affected package is buried countless layers deep in your supply chain.

SLA-Backed Remediation Timelines

FedRAMP’s new model puts pressure on your teams to treat exploitable, internet-reachable vulnerabilities almost like incidents: they need to be detected quickly and mitigated fast. 

Seal helps you keep pace with those expectations by providing:

• Prebuilt, CI-tested patches for open-source components
• Full audit trails for detection, mitigation, and remediation
• Metrics you can show to 3PAOs and agencies to prove performance, such as:
  
  • Up to 95% of critical/high vulnerabilities patched within 72 hours
    99% coverage across direct and transitive dependencies
  • Patch deployments in minutes, not months

You still own your FedRAMP obligations, but we give you a remediation engine that actually makes those obligations achievable.

End-to-End Coverage, For All Your Open Source

FedRAMP doesn’t just apply to application dependencies. If there is a vulnerability somewhere in your code, it must be mitigated or remediated in accordance with the guidelines above.

Luckily, Seal Security gives you coverage across the entire stack. We can help you secure all your open source, from application dependencies, base images, to containers. 

Even if your team is still reliant on a distro that no longer receives support such as RHEL 6/7 or CentOS 6/7, we can help you stay compliant without disruptions, with extended EOL patching support. 

See How Seal Security Supports Your FedRAMP Journey

If you’re aiming to achieve or maintain FedRAMP authorization under the new Vulnerability Detection and Response standard, scanners and dashboards alone won’t get you there. You need a way to:

• Continuously detect and prioritize based on context and exploitability
• Remediate at scale without breaking production or blowing up your roadmap
• Prove with data that you’re meeting FedRAMP’s vulnerability timelines

We help teams do all 3 of these with tools they can rely on. The Seal Security platform gives patch-in-place remediation across direct and transitive dependencies, SLA-backed CVE fixes that map cleanly to VDR timelines, and coverage that extends to legacy, containerized, and base-image layers, plus EOL systems.

If you’re updating your vulnerability program to align with FedRAMP’s Vulnerability Detection and Response standard, Seal can help you meet the new remediation timelines and provide clear evidence of what’s been fixed.

Request a demo to see how we support CSPs with continuous, automated vulnerability remediation, without constant upgrades, regressions, or missed SLAs.

Talk to us about VDR readiness, book a short demo today.