FedRAMP vs IRAP: Real-World Security, Not Just Paperwork

Cloud compliance isn’t just a checkbox — it’s a battleground. If you’re targeting government clients, you’re playing by strict, region-specific rules. And two of the toughest gatekeepers are FedRAMP (United States) and IRAP (Australia).

On the surface, they look similar: security frameworks, checklists, audits. But if you’ve ever tried to sell a FedRAMP-cleared SaaS into the Australian public sector — or IRAP-verified tech into the U.S. — you already know: they’re not the same beast.

This post breaks down:

• What FedRAMP and IRAP are, and how they came to be.
• Where IRAP diverges — especially around trust, sovereignty, and delivery process.
• How to support both without drowning in bureaucracy.

What is FedRAMP and IRAP?

Lets start at the top.

FedRAMP (Federal Risk and Authorization Management Program)
Launched in 2011, FedRAMP is a U.S. government-wide program that standardises security assessments, authorisations, and continuous monitoring for cloud products and services. It’s based on NIST SP 800-53 and governed by the Joint Authorisation Board (JAB), which includes the DoD, DHS, and GSA.

Its goal: centralise compliance and reduce redundant security assessments across U.S. federal agencies.


IRAP (Information Security Registered Assessors Program)
IRAP, developed by the Australian Signals Directorate (ASD), is not a certification program. It's a scheme for assessing how well a cloud service aligns with the Australian Government Information Security Manual (ISM). It started in the early 2010s as Australia’s public sector faced increased pressure to modernise securely.

Its goal: decentralise evaluation, allowing agencies to decide what’s good enough — based on the opinion of an ASD-accredited assessor.

Recap: What They're Both Trying to Do

At the core, FedRAMP and IRAP try to solve the same problem: reduce risk by enforcing security standards across cloud services used by government agencies.

Both:

• Reference strict control frameworks (FedRAMP: NIST 800-53; IRAP: ASD ISM).
• Require assessments by third-party professionals.
• Scale by sensitivity levels (FedRAMP: Low/Moderate/High; IRAP: Unclassified → Top Secret).
• Demand proof of things like access control, encryption, logging, patching, and incident response.

But that’s where the similarities end.

Key Difference 1: IRAP Isn't Certification — It's Trust and Acceptance

FedRAMP = centralised certification.
You go through:

• A 3PAO (Third Party Assessment Organisation)
• A JAB or agency sponsor.
• A long, structured approval process.

If successful, you’re listed in the FedRAMP Marketplace and you can reuse that authorisation across agencies. It’s like getting your security passport stamped — once you’re in, you’re in.

IRAP = decentralized assessment.
You engage an ASD-endorsed IRAP Assessor, who:

• Audits you against the ISM.
• Produces a report — no official certification.
• Leaves it to each agency to decide if they trust the findings.

So if the agency doesn’t like your setup — or your assessor? Doesn’t matter if you ticked every box. You’re out.

Key Difference 2: Physical Security — Where IRAP Goes Hard

FedRAMP focuses on virtual boundaries and logical controls — you inherit a lot from cloud providers like AWS GovCloud or Azure Government. Physical security is baked into their compliance.

IRAP, especially at Protected level and above, doesn’t take your cloud provider’s word for it. It wants hands-on validation.

Aspect	FedRAMP	IRAP (Protected+)
Data Location	Must stay in U.S. (for High)	Must be in Australia — full stop
DC Audits	Trust inherited from provider (SOC 2, etc.)	Assessor may demand photos, site visits, or original DC security docs
Personnel Access	Clearance optional	NV1/NV2 clearance often required for support/ops
Geo-fencing	Optional best practice	Mandatory

IRAP assumes threat actors. Hostile nations. Supply chain risks. Insider attacks. It's built for a zero-trust world where sovereignty trumps convenience, and be prepared to repeat your IRAP assesment for every Agency and EVERY major release. Change your architecture, platform services drop new features - your in reassesment territory and only a matter of time before this happens.

Key Difference 3: Your DevOps Pipeline Is Under the Microscope

A lot of teams nail the app security but forget the pipeline.
FedRAMP cares about:

• Documented change control.
• CI/CD audit trails.
• Pre-prod testing and rollback planning.

IRAP digs deeper:

• Strict segregation — no prod data in dev/test.
• Full MFA and logging on CI/CD infrastructure.
• Clear documentation for hotfixes, incident response, and access management.

They'll ask:

• “Who can deploy?”
• “Where are your secrets stored?”
• “What happens if your DevOps lead resigns tomorrow?”

If your DevOps is a mess, you’re toast.

You need:

• Role-based access control down to repo and pipeline level.
• Immutable, auditable deployment paths.
• Air-gapped or region-bound secrets handling.
• Named approvers per environment.

IRAP wants to see that your team can't cut corners — even if they try.

Cost, Time, and Effort

Framework	Time to Achieve	Cost Range (AUD)	Renewals	Complexity Drivers
FedRAMP Moderate	6–12 months	$500k–$2M+	Annual + 3-year reassessment	3PAO capacity, JAB coordination, documentation volume
IRAP (Protected)	2–4 months	$100k–$500k	At agency discretion	Assessor availability, ISM alignment, hosting model

This assumes youve already nailed Essential Eight. If not, buckle up - its about to get expensive!

Need Both? Here's How to Play It Smart

If you're building for dual compliance, don’t duplicate effort. Build smart:

• Use NIST 800-53 as your base - It’s the broader framework. Layer ASD ISM controls on top for IRAP, especially:
  Essential Eight maturity (Patch, App Control, Config Hardening, MFA, etc.)
  Geo-fencing and regional logging.
  Australian personnel and hosting.
  
• Split by region
  US workloads → FedRAMP-authorised zones (AWS GovCloud, Azure Government).
  AU workloads → Australian-hosted, IRAP-ready environments.
  
• Split DevOps infrastructure
  Separate pipelines and secrets stores per region.
  Named individuals for approval and audit per jurisdiction.
  

Don’t cross the streams — even for logs.

Closing: FedRAMP Is a Process. IRAP Is a Relationship.

FedRAMP is about compliance. It’s slow, methodical, predictable. You do the work, pass the test, get the badge.

IRAP is about trust. It's fast if you're prepared — but incredibly subjective. If your agency contact doesn't like your setup, or thinks your assessor phoned it in, your deal is dead. No appeal. No second shot.

So don’t just aim for certification. Aim for credibility.

Build real security.

Prove real sovereignty.

Earn real trust.

Because IRAP won’t give you points for what you say. It will judge you for what you’ve done — in Australia, with Australians, on Australian soil.