For Cloud Service Providers (CSPs) targeting the FedRAMP High baseline, the transition to Revision 5 has brought rigorous scrutiny to Identity and Access Management (IAM). Following the release of the updated FedRAMP authorization documents in December 2025, some confusion has circulated among CSPs: the belief that standard IAL2 identity proofing, if done "in-person," is sufficient for the High baseline.
This is incorrect.
At Trust Swiftly, we have analyzed the raw text of the most recent FedRAMP SAR Appendix B - High Security Requirements Traceability Matrix. The data is irrefutable: FedRAMP High requires Identity Assurance Level 3 (IAL3). In previous templates IAL3 was specifically a standalone statement in the traceability, but it is now slightly moved in separate columns for the documentation.
Here is the breakdown of the new requirements and why "enhanced IAL2" will cause you to fail your audit.
The "Hidden" Mandate in Control IA-5
If you only review Control IA-12 (Identity Proofing), the requirement seems ambiguous. The control text instructs CSPs to proof users based on the "appropriate identity assurance level." Many Compliance Officers mistakenly interpret "appropriate" as "IAL2," assuming IAL3 is too difficult to implement.
However, the specific mandate is located in Control IA-5 (Authenticator Management).
According to the FedRAMP High baseline text (Page 276 of the SSP Appendix A), the requirement is explicit:
"IA-5 Requirement: Authenticators must be compliant with NIST SP 800-63-3 Digital Identity Guidelines IAL, AAL, FAL level 3."
This single line closes the loop. You cannot bind an AAL3 authenticator (required for High) to an identity that was only proofed to IAL2 standards. The entire chain of trust—Identity (IAL), Authenticator (AAL), and Federation (FAL)—must be Level 3.
Why "IAL2 In-Person" is Not IAL3
We often hear CSPs ask: "If I verify a driver's license in person, isn't that IAL3?"
No it misses many security checks such as hardware level verification.
Under NIST SP 800-63 guidelines, the difference between IAL2 and IAL3 is not just physical presence; it is the rigor of the evidence validation.
IAL2: Validates that the evidence appears genuine and matches the applicant.
IAL3: Requires Cryptographic or Biometric validation of the evidence.
To meet IAL3, you cannot simply look at a license. You must verify the digital signature on the ID's chip or perform a biometric comparison (facial recognition) against the source of truth, all while the user is physically present or in a Supervised Remote session.
The Trust Swiftly Advantage: Solving IAL3 for FedRAMP High
Achieving IAL3 compliance internally is operationally expensive and technically complex. It requires specialized hardware, trained agents, and biometric processing capabilities that most CSPs do not possess. HR teams do not have the capacity alone to take on this role and require an auditable and secure process for employees.
Trust Swiftly abstracts this complexity. We provide the IAL3 layer required to satisfy FedRAMP High controls IA-12 and IA-5.
How We Map to the Dec 2025 Requirements:
IA-12 (Identity Proofing): We perform Supervised Remote Identity Proofing (SRIP). Our agents interact with your users via live video (meeting the "In-Person" equivalent standard recognized by FedRAMP), capturing and validating High-strength evidence.
IA-5 (Authenticator Management): We ensure the identity binding meets the IAL3 standard, allowing you to legally provision the required AAL3 hardware tokens (like YubiKeys or CACs).
SC-13 (Cryptographic Protection): Our verification processes utilize FIPS-validated cryptography for evidence validation, ensuring the integrity of the proofing event.
Conclusion
As of January 2026, the ambiguity is gone. If you are pursuing FedRAMP High, you cannot shortcut Identity Assurance. The baseline requires Level 3 across the board.
Don't risk a "Not Satisfied" finding in your SAR. Partner with Trust Swiftly to implement a frictionless, compliant IAL3 workflow that satisfies the most stringent federal requirements.
Key Takeaways for Your SSP (Rev 5)
Control IA-2: Requires Phishing-Resistant MFA.
Control IA-5: Explicitly mandates IAL3 / AAL3 / FAL3.
Control IA-12: Must use Supervised Remote or Physical In-Person proofing with biometric/crypto checks.
Contact Trust Swiftly today to ready your IAM architecture for FedRAMP High.