A Framework for Dual-Use Companies Navigating the Pathway to Authority to Operate
Ryan Gutwein
Extending MIT's Dual-Use Readiness Levels for ATO Strategy
MIT's Dual-Use Readiness Levels framework gave the defense tech ecosystem a shared language for measuring startup maturity across five dimensions: technology, commercial funding, commercial customers, mission funding, and mission customers. But for any software company selling into the Department of War or broader public sector, there is a sixth dimension that often determines whether a promising product ever reaches the warfighter: authorization to operate.
Authorization Readiness Levels (ARL) is a complementary framework that maps the pathway from "we know we need an ATO" to "we hold production authorizations across multiple agencies and pathways." It covers five distinct authorization pathways, each with its own 9-level progression from initial awareness through scaled, multi-agency operations.
For Founders
Assess where you are, plan where to go, and communicate your ATO strategy to investors and government stakeholders
For Investors
Evaluate authorization maturity and understand the timeline and investment required to unlock government revenue
For Gov Stakeholders
Understand where your vendor partners are in their authorization journey and what they need to advance
Federal civilian cloud authorization baseline under Rev 5 and the emerging 20x pathway
GSA / FedRAMP PMO
Risk Management Framework pathway through eMASS, governed by NIST 800-53 and DISA STIGs
DoW Authorizing Officials
DoW Cloud Computing SRG pathway to IL4, IL5, and IL6 Provisional Authorizations
DISA
DevSecOps-native pathway to continuous authorization, aligned with DoW Reference Design and SWFT
DoW Program AO
Cybersecurity Maturity Model Certification for protecting CUI across the defense industrial base
CMMC PMO / C3PAOs
Technology (TRL)
Architecture decisions at TRL 3-5 determine whether your system is authorizable at all
Mission Funding (MFRL)
SBIR and OTA awards increasingly expect authorization pathway plans as deliverables
Mission Customer (MCRL)
The Authorizing Official who signs your ATO is a mission customer stakeholder
Commercial Customer (CCRL)
FedRAMP authorization is increasingly valued as a trust signal in healthcare, finance, and critical infrastructure
Commercial Funding (CFRL)
Investors evaluate ATO readiness as a proxy for government revenue predictability
Every authorization pathway follows a universal arc from awareness through scaled operations. The specifics differ, but the shape is the same.
1
AWARE
2
SCOPE
3
GAP
4
REMEDIATE
5
SUBMIT
6
ASSESS
7
AUTHORIZE
8
OPERATE
9
SCALE
Levels 1-3
Discovery & Planning
Levels 4-6
Build & Assessment
Levels 7-9
Authorized & Scaling
The federal civilian baseline. FedRAMP operates under a unified authorization model since the JAB was dissolved in August 2024, with Rev 5 alignment and the emerging FedRAMP 20x continuous validation pathway replacing the traditional assessment cycle.
Read full pathway details in the whitepaper →The DoW-specific Risk Management Framework pathway, operationalized through eMASS and governed by NIST 800-53 and DISA STIGs. This is the pathway for systems deployed directly on DoW networks and enclaves.
Read full pathway details in the whitepaper →The DoW Cloud Computing Security Requirements Guide (CC SRG) pathway to IL4, IL5, and IL6 Provisional Authorizations, managed by DISA. Required for cloud services handling CUI and national security data.
Read full pathway details in the whitepaper →Each level includes detailed descriptions, examples, and actionable guidance
29-page whitepaper with all 5 pathways
The DevSecOps-native pathway to continuous authorization, aligned with the DoW Enterprise DevSecOps Reference Design and the Software Fast Track (SWFT) initiative. cATO replaces 3-year assessment cycles with ongoing, automated validation.
Read full pathway details in the whitepaper →The Cybersecurity Maturity Model Certification pathway for protecting CUI across the defense industrial base, governed by 32 CFR Part 170 and DFARS 252.204-7021. Affects an estimated 80,000+ contractors in the DIB.
Read full pathway details in the whitepaper →80K
contractors need CMMC Level 2 certification
<600
certified CMMC assessors available
$500K-$2M
typical FedRAMP Rev 5 authorization cost
33x
ROI on $1.5M FedRAMP investment unlocking $50M TAM
Authorization Readiness Levels interact with every dimension of MIT's framework. The following mapping shows typical alignment.
| Authorization Stage | Typical MIT Alignment | Key Implication |
|---|---|---|
| ARL 1-2 (Awareness, Scoping) | TRL 4-5, MFRL 1-2, MCRL 1-2 | Architecture decisions must be made with authorizability in mind. Most cost-effective time to design for compliance. |
| ARL 3-4 (Gap Analysis, Remediation) | TRL 6-7, MFRL 3-4, MCRL 3-4 | Compliance remediation should be funded -- SBIR Phase II, OTA, or seed/Series A should include ATO budget. Expect $500K-$2M for Rev 5; potentially much less under 20x. |
| ARL 5-6 (Assessment) | TRL 7-8, MFRL 5-6, MCRL 5-6 | The AO is a mission customer. Managing the assessment relationship is as important as the technology itself. |
| ARL 7 (ATO Granted) | TRL 8-9, MFRL 7, MCRL 7-8 | Authorization unlocks production revenue. The inflection point for mission customer conversion. |
| ARL 8-9 (ConMon, Multi-Agency) | TRL 9, MFRL 8-9, MCRL 8-9, CFRL 6+ | Sustained authorization is a competitive moat. Investors value it. Reuse and reciprocity accelerate growth. |
01Design for Authorization from Day One
The most expensive ATO decision is the one you don't make early enough. Selecting a FedRAMP-authorized IaaS provider, implementing FIPS-validated encryption, and designing your system boundary at TRL 3-5 saves 6-12 months and hundreds of thousands of dollars compared to retrofitting at TRL 7-8.
02The AO Is a Customer, Not a Gatekeeper
The Authorizing Official and their team (ISSM, ISSO, SCA) are mission customer stakeholders. Build relationships early, understand their risk appetite, and treat the process as a partnership.
03Fund Authorization Like a Product Feature
ATO is not overhead -- it is a product feature that unlocks an entire market. Budget for it in SBIR proposals, include it in OTA milestones, and present it to investors as go-to-market infrastructure. A $1.5M FedRAMP investment that unlocks $50M in addressable government revenue is a 33x leverage play.
04Leverage Inheritance and Reciprocity
Build on FedRAMP-authorized IaaS/PaaS to inherit 50-70% of the control baseline. Leverage reciprocity between DoW organizations. Use your FedRAMP authorization as the foundation for DoW RMF and IL authorization.
05Build Toward Continuous, Not Just Compliant
FedRAMP 20x replaces narrative SSPs with machine-readable KSIs and persistent validation. DoW cATO replaces 3-year cycles with continuous monitoring. FedRAMP aims to stop accepting new Rev 5 packages by late FY27 -- the transition window is now.
06Treat Authorization as a Competitive Moat
Every additional agency ATO, every IL level, every year of ConMon history widens the moat. Protect and maintain your authorizations -- they are among your most valuable business assets.
07Understand the Institutional Map
FedRAMP is managed by the FedRAMP PMO at GSA. IL PAs are managed by DISA under the CC SRG. DoW RMF ATOs are issued by individual AOs through eMASS. CMMC certifications are managed by the CMMC PMO with C3PAOs and DIBCAC. Understanding which institution owns which authorization prevents wasted effort.
FedRAMP
GSA
FedRAMP PMO + Board
DoW RMF
DoW AOs
eMASS + DoDI 8510.01
IL PA
DISA
CC SRG
cATO
DoW Program AO
DevSecOps Ref Design
CMMC
CMMC PMO
C3PAOs + DIBCAC
29-page whitepaper with all 5 pathways x 9 levels, detailed examples, MIT alignment mapping, and procurement guidance.
Download PDF →FedRAMP 20x promises streamlined cloud authorizations. But across DoW, civilian agencies, and the IC, the real challenge is institutional inertia.
Read blog >>The ATO process was designed to manage risk. Instead, it has become the risk — delaying deployments by 12 to 18 months.
Read blog >>A practical guide to architecting a CI/CD pipeline across the authorization boundary for FedRAMP, DoW IL, and agency ATO environments.
Read blog >>See how Optimal can accelerate your path to ATO while strengthening your security posture.