The Cybersecurity Maturity Model Certification (CMMC) was created to establish a uniform standard for cybersecurity practices, specifically targeting organizations within the Defense Industrial Base (DIB). This model ensures that entities handling sensitive data, including Controlled Unclassified Information (CUI), Critical Technology Information (CTI), Federal Contract Information (FCI), and ITAR data, are able to safeguard such information adequately. To support DoD contractors in their compliance journey, the CMMC Accreditation Body (CMMC-AB) offers various certifications, including C3PAOs (CMMC Third-Party Assessment Organizations).
In this article, we focus on the role of a C3PAO, a key player in ensuring organizations meet the CMMC standards.
What Exactly is a C3PAO?
A CMMC Third-Party Assessment Organization (C3PAO) is a group authorized by the CMMC-AB to perform official assessments of an Organization Seeking Compliance (OSC). Once an OSC enters into a contract with a C3PAO, the latter conducts a thorough evaluation to determine whether the OSC complies with the necessary CMMC level.
In essence, C3PAOs play a crucial role in helping contractors in the DIB become certified by assessing their alignment with CMMC standards. It’s important to note that C3PAOs focus solely on conducting assessments—they do not provide consulting services, as this would create a conflict of interest. To assist in the pre-assessment phase, organizations often rely on Registered Provider Organizations (RPOs). RPOs offer guidance on compliance, help with policy creation, and ensure that the systems are configured to meet CMMC requirements. However, a C3PAO cannot act as both an RPO and an assessor for the same organization to maintain objectivity.
For contractors handling FCI or CUI, encountering the DFARS 7021 clause in their contracts is inevitable. As the Department of Defense (DoD) implements CMMC, contractors will be required to undergo these assessments before their contracts are renewed. By 2025, all DoD contracts will contain this clause, making CMMC compliance a key requirement for doing business with the DoD.
How Does a C3PAO Assessment Work?
To determine which CMMC level an organization should pursue, contractors must assess their contracts to understand the cybersecurity requirements. Once this is clear, a C3PAO conducts an assessment based on the specific level of compliance required. This includes evaluating domains and practices in line with the desired CMMC level. As of now, C3PAOs are still in the process of being fully authorized to assess OSCs, but once they are, the process will become an integral part of CMMC certification.
In certain cases, a C3PAO may work under contract with a Certified CMMC Assessor (CCA) to conduct the assessment. If you’re unsure of the level your organization needs to achieve, consulting a C3PAO is the best next step.
Steps to Become a C3PAO
Becoming an official C3PAO is a detailed process involving several steps, including:
- Ownership Requirements: The organization must be 100% US-citizen owned or undergo a Foreign Ownership, Control, or Interest (FOCI) investigation if the company is public, has an Employee Stock Ownership Plan (ESOP), or operates as a global partnership.
- CMMC Level 3 Compliance: The organization must pass an audit verifying its compliance with CMMC Level 3 standards.
- Organizational Background Check: The C3PAO is subject to a background check by the CMMC-AB through Dun & Bradstreet. The company must also have a DUNS number and be registered in the CMMC-AB Marketplace.
- ISO 17020 Certification: The organization must hold an ISO 17020 certification.
- Insurance and Liability Policies: The C3PAO must carry general liability insurance, including errors and omissions and cybersecurity breach policies.
- Partnerships: The C3PAO must have a relationship with at least one Registered Practitioner (RP), Certified CMMC Professional (CCP), CMMC Assessor (CCA), or Professional Assessor (PA).
- Annual Fee: A $3,000 USD annual fee is required to maintain C3PAO certification.
If the C3PAO uses a Cloud Service Provider (CSP) to handle or store CUI data, it must ensure that the CSP meets FEDRAMP High standards or that any gaps are properly addressed.
Choosing the Right C3PAO for Your Organization
Selecting the right C3PAO is crucial to ensuring your compliance journey runs smoothly. A reputable C3PAO will not only guide you through the assessment process but also ensure that your organization meets all necessary cybersecurity requirements as you prepare for CMMC certification.
Working with a C3PAO is essential for contractors aiming to secure and retain DoD contracts. Without CMMC certification, contractors may lose the ability to bid on or participate in DoD projects. C3PAOs not only verify compliance but also help organizations strengthen their overall cybersecurity posture, ensuring long-term protection of sensitive data and operational integrity.
How Can Netizen Help?
Netizen ensures that security gets built-in and not bolted-on. Providing advanced solutions to protect critical IT infrastructure such as the popular “CISO-as-a-Service” wherein companies can leverage the expertise of executive-level cybersecurity professionals without having to bear the cost of employing them full time.
We also offer compliance support, vulnerability assessments, penetration testing, and more security-related services for businesses of any size and type.
Additionally, Netizen offers an automated and affordable assessment tool that continuously scans systems, websites, applications, and networks to uncover issues. Vulnerability data is then securely analyzed and presented through an easy-to-interpret dashboard to yield actionable risk and compliance information for audiences ranging from IT professionals to executive managers.
Netizen is a CMMI V2.0 Level 3, ISO 9001:2015, and ISO 27001:2013 (Information Security Management) certified company. We are a proud Service-Disabled Veteran-Owned Small Business that is recognized by the U.S. Department of Labor for hiring and retention of military veterans.
