From Barrier to Bridge: The Hope of FedRAMP Waivers (OMB M-24-15)

Executive Summary

OMB Memo M-24-15 introduces a structural shift in how the federal government authorizes cloud products—offering agencies a formal pathway to waive FedRAMP requirements for narrow-scope, mission-critical solutions.

It’s not a shortcut. It’s a bounded, policy-backed on-ramp for emerging SaaS and PaaS offerings that face real adoption barriers despite agency demand.

For CXOs, the waiver isn’t just a compliance artifact. It’s a strategic tool—a way to unlock momentum, access funding, and demonstrate value without delaying impact.

What the Policy Enables

M-24-15 gives agencies the authority to request FedRAMP waivers for cloud solutions that are:

• Critical to mission execution

• Scoped for a single agency or enclave

• Time-bound or limited in deployment

It shifts the trust model from centralized pre-clearance to agency-specific risk acceptance—framed by governance, documentation, and oversight.

“An agency may request a waiver… for cloud offerings that are limited in scope, time-bound, and critical to mission execution.”— OMB Memo M-24-15, Section IV

This isn’t about reducing risk. It’s about realigning trust to fit the urgency and shape of the mission.

OMB Memo M-24-15 enables a pathway for agencies to accelerate the onboarding of emerging SaaS and PaaS solutions without compromising oversight.

What It Requires

The memo offers acceleration—but not exemption. To be effective, a waiver must be built on:

• Defined scope: Clear boundaries for use, ownership, and data handling

• Lifecycle transparency: From waiver initiation to renewal or decommission

• Deployment architecture: Support for strong tenant isolation to ensure bounded risk, mission-specific control, and clear authorization boundaries

• Agency governance: Oversight frameworks that satisfy agency and OMB review

“Waiver approval is subject to agency risk acceptance and review by OMB.”— OMB Memo M-24-15, Section IV

Even in the express lane, you still need a map of the infrastructure for transparency.

What It Unlocks

For emerging products—especially those with single-agency utility, time-sensitive missions, or bounded use cases—M-24-15 provides legitimized market access without demanding a full-scale FedRAMP process out of the gate.

Used well, it can:

• Accelerate agency onboarding

• Enable funded execution for early deployments

• Demonstrate field impact while maintaining oversight

• Position the product for long-term authorization or reuse

But misused—or misunderstood—it can anchor you to a limited deployment model, slow future authorizations, or strain delivery teams unprepared to operate as “trusted” from day one.

The Strategic Litmus Test

Before pursuing a waiver, leadership teams should ask:

• Are we ready to deliver as if fully authorized?

• Will this path support scale—or box us in?

• Do we have the architecture, governance, and clarity to justify agency trust?

The waiver isn’t a workaround. It’s a bridge—one that only works if you’ve structured your product, your support model, and your trust posture to walk across it.

The PSF Perspective

At PSF, we see M-24-15 not as an escape hatch—but as a bridge for mission-ready, emerging products whose architecture and delivery models are already aligned with trust—even if they haven’t yet completed FedRAMP.

We help clients evaluate whether the waiver creates forward momentum or masks structural gaps—because policy flexibility means nothing without product readiness.

Used wisely, M-24-15 doesn’t replace FedRAMP.

It builds toward it—on your terms.