Cloud service providers seeking FedRAMP High authorization confront a major compliance challenge: Identity Assurance Level 3 (IAL3).
Unlike lower levels of assurance, IAL3 is not just a software toggle or a new MFA policy. It is a supervised, evidence-heavy workflow that combines identity proofing, trained operators, controlled devices, logistics, and audit documentation.
NIST SP 800-63A-4 requires a supervised physical or supervised remote element for IAL3 identity proofing. But how do you achieve that when your workforce is distributed? Many vendors can solve part of the workflow; enterprise buyers need to understand which provider can support the full operating model.
Here is how to evaluate IAL3 providers for remote teams, and where Trust Swiftly fits when you need managed hardware, trained proofing agents, logistics, and audit-ready evidence.
The Three Pillars of a True IAL3 Solution
To support IAL3 compliance under NIST SP 800-63A-4, a solution must deliver three critical components. If one of these is missing, your compliance, security, and operations teams may need to own the gap.
- Managed Hardware: IAL3 workflows depend on controlled equipment for high-quality biometric and document capture. Relying only on an applicant's unmanaged personal device can create audit and attack-surface concerns.
- Trained Agents: Technology alone is not enough. NIST IAL3 workflows require a trained proofing agent or trusted referee to oversee the session, verify the applicant's presence, and inspect identity evidence.
- End-to-End Logistics: You need a reliable, secure pipeline to get that managed hardware into the hands of your remote user—and back again—without compromising the device or the data.
Why Trust Swiftly Is Built for Full-Workflow IAL3
Trust Swiftly recognized that forcing modern SaaS companies to build in-house physical security, proofing operations, and shipping processes was unsustainable. Our platform bundles the core pieces that remote IAL3 programs need: managed hardware options, supervised proofing workflows, logistics support, and structured evidence packages.
1. Zero-Footprint Logistics
For a private vendor with remote employees, the biggest hidden cost of IAL3 is shipping and tracking. Trust Swiftly supports a managed hardware loop: shipping the secure IAL3 kit to the employee's residence, monitoring return tracking, and executing device sanitization after use. This lets security and compliance teams stay focused on the FedRAMP assessment instead of becoming a hardware operations team.
Trust Swiftly's managed hardware loop eliminates the operational burden of IAL3 logistics. The secure kit ships directly to the remote employee, a supervised proctoring session is conducted, and the device is returned and cryptographically sanitized—all without your team lifting a finger.
2. Integrated "Proctoring-as-a-Service"
NIST requires a trained agent to verify the applicant's presence and inspect identity evidence. Hardware alone still leaves you responsible for staffing, training, quality control, and operating procedures. Trust Swiftly can provide supervised proofing agents and workflows designed around NIST 800-63A-4 evidence requirements, including video, liveness checks, document inspection, and session records.
3. Built for the Modern "FedRAMP High" Audit
Legacy identity systems were often designed for DMV, TSA, or on-premise government facility workflows. Trust Swiftly was built for Cloud Service Providers and distributed teams. We provide structured chain-of-custody artifacts and evidence packages that can be reviewed during a FedRAMP High assessment, turning a cumbersome physical requirement into a predictable, API-driven process.
4. Adaptive and Flexible Verification Evidence Pathways
Legacy identity proofing solutions can be rigid, accepting only a narrow set of document types and rejecting anything that falls outside their playbook. In the real world, employees relocate, documents expire, and not everyone carries the same set of credentials. Trust Swiftly supports adaptive evidence pathways, allowing applicants to verify identity using approved documentation such as a current passport, a state-issued ID, or a combination of supplementary evidence. This helps reduce unnecessary friction while preserving the evidence quality compliance teams need.
Common Mistakes When Evaluating IAL3 Solutions
Navigating the vendor landscape can be tricky. Here are the four most common traps organizations fall into when trying to solve the IAL3 puzzle.
Mistake 1: Thinking Software (Ping/Okta) is Enough
Many IT teams assume their existing Identity Provider (IdP) can simply "turn on" IAL3. In practice, IdPs handle authentication and access policy, while IAL3 requires supervised identity proofing evidence. You can absolutely use Ping, Okta, or Entra ID for Authentication Assurance Level (AAL) controls, but the Identity Assurance Level (IAL) phase requires a dedicated proofing workflow.
Mistake 2: Buying Hardware Without Agents
There are several vendors on the market selling "mobile enrollment kits." However, if you buy a kit from a manufacturer, you are now responsible for hiring, training, and retaining the agents to man those kits. For a private tech vendor, this creates a massive and ongoing operational burden. Simply put: if the solution doesn't include the human proctor, it isn't a full solution.
Mistake 3: Assuming Industry Certifications (like Kantara) Are the Only Path
Industry certifications, such as Kantara, provide valuable and respected frameworks for identity assurance. However, a third-party badge is not a substitute for reviewing how the workflow maps to your authorization boundary, system security plan, and 3PAO expectations. Organizations should look for solutions that can document alignment to NIST 800-63A-4 while still delivering the API architecture, flexibility, and operating speed required by remote-first SaaS companies.
Mistake 4: Ignoring the "Return Trip"
IAL3 kits can capture highly sensitive biometrics, documents, and device artifacts. A common risk is choosing a vendor that helps you buy the kit but leaves recovery and sanitization to your internal team. Trust Swiftly's managed return and wiping process helps maintain the chain of custody required for high-impact environments.
The Bottom Line
For private vendors with a distributed workforce, achieving IAL3 can feel operationally heavy. Trust Swiftly helps reduce the "physicality" barrier of remote identity proofing.
By bundling managed hardware, trained agents, and turn-key logistics, Trust Swiftly gives remote teams a practical path to IAL3 without requiring them to build a physical security office or shipping department.
Ready to simplify your path to FedRAMP High? Contact Trust Swiftly today for a consultation and see how our IAL3 solution can support your compliance journey, remote workforce, and high-assurance identity proofing program.