This study delves into the relatively uncharted territory of Above Threshold Ionization in atoms, triggered by intense X-ray radiation fields. At these frequencies, the energy of a single photon far exceeds the ionization potential of valence electrons in atoms and molecules. The conditions we examine are similar to those achievable with current or future free-electron laser facilities. Under such high-energy scenarios, the onset of strong field ionization requires a shift away from the traditional quasi-classical approach. Here, we present an analytical model to characterize how the field-free ionization potential, ponderomotive energy, and photon energy govern the transition to this regime, all accounted for by means of the Keldysh and Reiss parameters. We show that both of these parameters are needed to capture the onset of strong-field behavior due to both bound state and continuum state properties. At higher X-ray intensities, we find that ionization rates deviate from the linear intensity scaling expected from lowest order perturbative processes, corresponding to channel closure and higher-order photon absorption processes.