Securing an Authority to Operate (ATO) is a critical milestone for any contractor working with federal systems. But here’s the uncomfortable truth: most ATO efforts don’t go smoothly. And many never reach full authorization at all.
If you’ve tried to navigate the ATO process, you already know it can feel overwhelming, unclear, and frustrating. In this article, we’ll unpack why ATO efforts fail and how to avoid common missteps so your team doesn’t waste time, money, or opportunities.
What Is an ATO?
An Authority to Operate (ATO) is formal approval granted by a federal agency that allows your system or product to operate in a government environment. It confirms that your system meets required security controls and risk thresholds, typically based on NIST SP 800-53 or other federal frameworks.
No ATO = no launch. No production use. No data handling. It’s a gate you have to pass through to participate in many federal contracts.
Why Most ATO Efforts Fall Short
Let’s break down the most common failure points.
1. Unclear Ownership and Accountability
Many teams assume “someone else” is leading the ATO process. until it’s too late. Without a clear internal owner, deadlines get missed, documentation falls through the cracks, and the effort drags on indefinitely.
How to avoid it: Assign a single point of contact who owns the ATO lifecycle from start to finish. Give them the authority to coordinate across technical, legal, and executive teams.
2. Poor System Documentation
You can’t get an ATO without proving how your system works, how it protects data, and what risks it introduces. Missing or incomplete documentation (SSP, POA&M, risk assessments, diagrams, procedures) is one of the most common reasons ATOs stall.
How to avoid it: Start documentation early. Don’t wait for auditors or third parties to request it. Build a documentation culture as you build your system.
3. Trying to “Retrofit” Compliance
Many companies build their product or system first, then try to wrap compliance around it at the end. This almost always leads to costly rework or disqualification.
How to avoid it: Design with compliance in mind from day one. If that ship has already sailed, bring in a consultant who can help you map controls to your existing architecture realistically.
4. Not Understanding the Agency’s Risk Tolerance
Different agencies interpret and enforce security guidelines differently. What works for one sponsor may not pass muster with another. Assuming all ATOs follow the same rules can be a costly mistake.
How to avoid it: Build a relationship with the Authorizing Official (AO) and ask direct questions about risk appetite, documentation expectations, and process steps. Treat this like a stakeholder management exercise. Not just a checklist.
5. Overengineering the Security Stack
Some teams panic and overengineer their environment to ” look more secure.” However, bloated security architecture without a clear rationale can raise red flags and create new risks or complexity.
How to avoid it: Stick to what’s required. Use a risk-based approach to implement the proper controls for your system’s impact level. More isn’t always better.
6. Underestimating Timelines and Costs
ATO efforts can take 6 to 18 months, depending on scope, documentation quality, and agency responsiveness. Teams that budget for a 60-day turnaround or skip project management often hit a wall.
How to avoid it: Set realistic expectations—plan for delays. Build in buffer time, and be transparent with leadership about how long this process takes.
What Success Looks Like
Successful ATOs tend to have a few things in common:
Final Thought
The ATO process isn’t broken. But it is complex and often misunderstood. Most failures don’t happen because of technical weakness. They happen because teams underestimate what’s required and who needs to be involved.
At Black Rock Engineering & Technology, we help companies move through the ATO process with less friction and more confidence. From roadmap to readiness to full authorization, we help ensure your investment leads to clearance. Not confusion.
Need help navigating your ATO?
Get clarity on what it takes to move forward without hitting a wall.