H33-74 / Regulatory

H33-74 for FedRAMP

Federal Risk and Authorization Management Program requires verifiable evidence of operational controls. H33-74 produces that evidence as a chain-portable post-quantum proof that survives the systems and chains it was anchored to.

Federal Risk and Authorization Management Program (United States, cloud service providers and federal agencies) places obligations on organizations to demonstrate that operational controls were in place, that automated decisions were governed, and that an audit trail exists for regulatory inquiry. Most existing audit-log architectures meet the letter of the requirement but produce evidence tied to the operator's current systems. If those systems change or fail, the evidence weakens.

H33-74 produces audit evidence that survives the system that produced it. The proof is cryptographically verifiable independent of the operator. The PQ signatures survive the quantum transition. The chain anchors survive any single chain's deprecation.

What FedRAMP requires

FedRAMP requires cloud service providers to demonstrate continuous compliance with NIST SP 800-53 controls including audit and accountability (AU family), system and information integrity (SI family), and configuration management (CM family). The 3PAO assesses controls annually and the agency authorizing official reviews continuous monitoring evidence on an ongoing basis. Authorization horizons extend across multi-year ATO cycles.

Why H33-74 fits

FedRAMP continuous monitoring requires evidence that controls have operated continuously over the authorization period, including across infrastructure transitions, contractor changes, and tooling updates. H33-74 produces each privileged action, each configuration change, each security event, and each access decision as a cryptographically verifiable proof. The 3PAO and the agency AO can verify the operation of any control directly, independent of the CSP's current logging and monitoring stack.

Control mapping

AU-2 / AU-3 — Audit events
Each auditable event emits a proof. The audit log becomes a sequence of independently verifiable cryptographic objects.
AU-9 — Protection of audit information
Audit integrity is structural via PQ signatures, not contractual via log protection controls.
CM-3 — Configuration change control
Each configuration change emits a proof including the requester, approver, change content, and rollback path.
IR-4 — Incident handling
Each incident classification, containment decision, and recovery action emits a proof. The incident response audit trail survives the SIEM that produced it.
SI-4 — System monitoring
Each monitoring detection and disposition emits a proof. Continuous monitoring evidence becomes chain-portable.

What this changes for the audit team

The FedRAMP audit trail becomes chain-portable evidence. Each control's record outlives the system that produced it, the vendor that hosts it, and the chains it was anchored to.

The chain-portable evidence model

Read the architectural concept underneath every H33-74 regulatory deployment.

Chain Portability Why Chain Migration Shouldn't Exist

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