Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Zoho Docs
by Zoho
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Office Suite
Overview
Zoho Docs provides online document editing and storage within the Zoho ecosystem. It is not FedRAMP authorized and cannot be used for government CUI document workflows.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Zoho Docs has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO must immediately add Zoho Docs to the POA&M as a high-risk finding under DFARS 252.204-7012 non-compliance.
- 2Contracts officer should review all active contracts to identify CUI requirements and notify program managers of immediate migration needs.
- 3System administrator must conduct comprehensive data inventory to identify all CUI documents stored in Zoho Docs platform.
- 4ISSO shall update the authorization boundary diagram to exclude Zoho Docs from any CUI processing workflows.
- 5Legal counsel must review data export procedures to ensure compliance with data residency requirements during migration.
- 6System administrator should implement approved alternative platform (Microsoft 365 GCC High or Google Workspace for Government).
- 7ISSO must update System Security Plan (SSP) to reflect new compliant document collaboration platform implementation.
- 8Training coordinator should conduct mandatory user training on new platform emphasizing CUI handling procedures.
- 9System administrator must securely delete all organizational data from Zoho Docs and obtain deletion certification.
- 10ISSO shall update continuous monitoring procedures to prevent future unauthorized cloud platform adoption.
NIST 800-171 Violations
Using Zoho Docs for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Related Compliance Assessments
Frequently Asked Questions
Is Zoho Docs FedRAMP authorized?
No. Zoho Docs and the broader Zoho platform do not hold FedRAMP authorization.
Can I use Zoho Docs with CUI?
No. Zoho Docs is not authorized for CUI document creation or storage. Use a FedRAMP authorized office suite instead.
What is a compliant alternative to Zoho Docs?
Microsoft 365 GCC High (FedRAMP High) and Google Docs Government (FedRAMP Moderate) are authorized alternatives.
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