CMMC C3PAO: Discover the Benefits of Working With a Third-party Assessor for CMMC 2.0 Compliance

The Cybersecurity Maturity Model Certification (CMMC) is a centralized cybersecurity framework established for organizations in the Defense Industrial Base (DIB) in the U.S. Department of Defense (DoD). It was established to help these organizations secure sensitive data such as Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).

CMMC 2.0 is designed to ensure that DoD organizations have the necessary security controls in place to protect the sensitive data from unauthorized access, use, disclosure, disruption, modification, or destruction. DoD contractors and subcontractors must demonstrate compliance with CMMC 2.0 in a phased implementation expected to begin Q1 2025.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

To assist the DoD contractors to achieve compliance, the CMMC Accreditation Body (CMMC-AB) authorized CMMC Third Party Assessor Organizations (C3PAOs) to help DoD contractors along the compliance journey. To achieve compliance with CMMC 2.0 mandates, DoD suppliers must appoint a C3PAO to assess their compliance.

In this blog post, we will discuss how a C3PAO fits into CMMC 2.0 compliance and what role they play in helping organizations achieve certification. We will also discuss the benefits of working with a C3PAO and how they can help organizations prepare for their CMMC assessment.

What Is a CMMC C3PAO?

A CMMC C3PAO is a CMMC Third Party Assessor Organization (C3PAO) authorized and certified by the CMMC Accreditation Body (CMMC-AB) to conduct assessments of contractors and subcontractors seeking certification to demonstrate compliance with the CMMC standard.

C3PAOs are entrusted with assessing and certifying that companies in the DIB supply chain have met the cybersecurity requirements of the CMMC standard. Their responsibilities include evaluating and issuing certificates of adherence to the CMMC standard.

The C3PAO must review and certify the contractor or subcontractor’s audit and self-assessment reports based on the DoD’s Cybersecurity Maturity Model. The C3PAO must also be able to recommend and implement corrective actions as needed. Lastly, the C3PAO is responsible for working with the DoD to ensure that the CMMC standard remains up to date with the latest technology and security measures.

Are Organizations Required to Work with a CMMC 3PAO?

Yes, it is mandatory for organizations to work with a C3PAO in order to achieve CMMC compliance. For a company to meet CMMC requirements, it must be evaluated by a C3PAO. These independent assessment organizations are authorized by the CMMC Accreditation Body to conduct and finalize CMMC assessments. This means, in order to keep your company cyber secure and maintain contracts with the DoD, you need to engage with a trusted C3PAO for a comprehensive and accurate assessment of your cybersecurity controls and practices.

In essence, utilizing a C3PAO is an essential step in achieving CMMC compliance. To put it simply, CMMC compliance and C3PAO go hand in hand for organizations targeting business opportunities with the DoD.

What is an Authorized CMMC C3PAO?

An Authorized CMMC C3PAO is a professional entity that has been certified to assess the cybersecurity maturity of companies, particularly those that work with the DoD.

These organizations play a crucial role in strengthening national security by identifying and rectifying potential vulnerabilities in the defense industrial base’s cyber infrastructure.

As an authorized C3PAO, they have met rigorous standards set by the CMMC Accreditation Body (AB), proving their capability to effectively evaluate a company’s adherence to the prescriptive practices and processes outlined in the CMMC framework. This certification offers a robust assurance of the organization’s commitment to maintaining high levels of cybersecurity.

CMMC C3PAO Authorization Phases

The process of becoming a CMMC C3PAO involves several phases, each requiring compliance with specific requirements. The authorization levels include:

CMMC C3PAO Authorization Phase 1: Candidacy

Phase One is the Candidacy phase, which includes several steps an organization must fulfill to be considered a CMMC C3PAO candidate, such as following the application process on the CMMC-AB website. This process involves signing a C3PAO License Agreement, providing verification of insurance, paying a nonrefundable application fee of $1,000, and paying a $2,000 activation fee. Once these four application steps are completed successfully, the company becomes a Candidate C3PAO.

DIBCAC Assessment

The Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) is responsible for conducting CMMC Maturity Level 3 assessments on Candidate C3PAOs, in order for them to become authorized. DIBCAC evaluates C3PAO candidates using questionnaires and scrutinizes their ability to field assessors. DIBCAC also pre-screens and schedules assessments for some selected C3PAOs. Passing the CMMC assessment of their information system is a crucial step in becoming an official C3PAO.

CMMC C3PAO Authorization Phase 2: Approval

Phase Two is the Approval phase, which requires the CMMC C3PAO candidate to undergo an organizational background check by Dun & Bradstreet. The candidate organization must also demonstrate it holds a CMMC-related registration or certification, and is 100% U.S. citizen owned. In the event the candidate organization is a foreign entity, it must undergo a Foreign Ownership, Control or Influence (FOCI) background investigation.

CMMC C3PAO Authorization Phase 3: Authorization

Phase Three is the Authorization phase, which requires the CMMC C3PAO candidate to demonstrate to the CMMC-AB that it has the necessary resources and personnel to sustain C3PAO Authorization and perform assessments. This phase also requires the candidate organization to demonstrate ISO 17020 certification within 27 months from the date of registration.

Although CMMC C3PAO certification requires significant investment, becoming a CMMC C3PAO can be a lucrative endeavor in the long term. Costs associated with C3PAO certification may include insurance, assessment, personnel, and other expenses. However, by participating in the emerging ecosystem of CMMC compliance services as the program rolls out, C3PAOs can unlock new business opportunities. Additionally, this certification can assist C3PAOs in safeguarding their own sensitive information against cyberattacks and data breaches.

How Does a C3PAO Help Organizations Achieve CMMC 2.0 Compliance?

A C3PAO is critical to achieving CMMC 2.0 compliance. C3PAO assessors evaluate an organization’s existing policies, processes, and controls against the CMMC requirements. They review existing security documentation, conduct interviews, and perform on-site inspections of systems and physical security. After assessing the organization’s current level of compliance, the C3PAO provides a report on their findings. This report will be submitted to the CMMC Accreditation Body for review, evaluation, and certification.

The C3PAO provides an independent review of an organization’s security posture, which gives the organization the assurance that their systems are secure and compliant. The C3PAO assessment also helps DoD suppliers to identify any deficiencies so that they can quickly address any gaps in their security posture. The C3PAO is an important part of the CMMC compliance process and is critical in ensuring that companies meet the required levels of security and compliance. The C3PAO helps organizations ensure that they meet CMMC 2.0 requirements and ultimately provide a secure environment for their customers and other stakeholders.

CMMC 2.0 contains three tiers of assessments based on the level of information access:

CMMC 2.0 Compliance Level 1: Foundational

Organizations pursuing CMMC 2.0 Level 1 certification must undergo an annual self-assessment with attestation from a corporate executive. This level encompasses the basic safeguarding requirements for FCI specified in FAR Clause 52.204-21.

CMMC 2.0 Compliance Level 2: Advanced

Organizations pursuing CMMC 2.0 Level 2 certification must demonstrate alignment with National Institute of Standards & Technology SP 800-171 (NIST SP 800-171). It requires triennial third-party assessments for DoD contractors that send, share, receive, and store critical national security information. These third-party assessments are conducted by C3PAOs. Select contractors that fall into Level 2 only require annual self-assessments with corporate attestation.

This level encompasses the security requirements for CUI specified in NIST SP 800-171 Rev 2 per DFARS Clause 252.204-7012 [3, 4, 5].

CMMC 2.0 Compliance Level 3: Expert

Level 3 will contain all 110 requirements from Level 2, plus an additional 24 requirements from SP 800-172, which is designed for protecting CUI against advanced persistent threats (APTs). Level 3 is anticipated to represent a smaller, more focused group of defense contractors that possess capabilities critical to national security interests. The specific requirements and assessment methodology for this level have been defined by the DoD in the Level 3 Guide and within Final Rule 32 CFR.

Assess and Monitor Risks with a C3PAO

The goal of C3PAOs is to identify security vulnerabilities, assess the risks associated with these vulnerabilities, and recommend mitigation strategies for addressing them.

C3PAOs use several different methods to assess and monitor risk. First, they conduct reviews of an organization’s existing and proposed security programs. During these reviews, C3PAO personnel gain a deep understanding of the organization’s security environment, which allows them to identify potential risks. Additionally, they may perform vulnerability scans and penetration tests to actively identify potential security weaknesses. These scans and tests can also provide valuable information about how secure the organization is, and which areas need to be addressed.

C3PAOs also provide ongoing monitoring of an organization’s security environment. This includes scanning for new threats and vulnerabilities, as well as keeping track of changes in the organization’s security posture. This allows them to quickly identify any potential gaps or weaknesses that may exist, and to recommend appropriate actions for addressing them.

C3PAOs help organizations assess their response to cyber incidents. This includes evaluating the organization’s readiness to respond, identifying gaps and weaknesses in its incident response plans, and making recommendations for improving the response. This helps organizations better prepare for, and more quickly respond to, future threats and incidents.

C3PAOs provide organizations with invaluable expertise in assessing and monitoring cyber risks. By leveraging their knowledge and experience, organizations can take proactive steps to reduce their risk and ensure that their overall security posture is as robust as possible.

Implement Continuous Monitoring and Automation with a C3PAO

A C3PAO can help organizations implement continuous monitoring and automation since they are familiar with security standards, industry best practices, and tools to assist with assessing the security of systems and applications. Among the services a C3PAO can offer in helping an organization implement continuous monitoring and automation are those related to system hardening and assessment. This includes helping to identify and configure security controls, developing security checklists, and conducting vulnerability assessments and penetration testing. It also includes working with the organization to develop audit and monitoring plans to ensure that security controls remain effective and to identify any weaknesses. It is important to note here that CMMC 2.0 requires a triannual third-party audit for certification at Levels 2 and 3.

A C3PAO can also help with the development of the organization’s security policy and procedures as they relate to CMMC 2.0 Level 2 practice controls. This includes identifying security objectives and associated risks, implementing appropriate safeguards, and creating documents such as security policies, standards, and guidelines. Further, a C3PAO can provide training and awareness programs to ensure that employees are aware of their role in maintaining the security of the organization’s systems.

A C3PAO can assist with the implementation of continuous monitoring tools. These include log review tools, vulnerability scanners, and network traffic analysis tools. A C3PAO assists with the setup of the tools, monitoring them for any suspicious activity and developing reports to keep senior staff informed. A C3PAO is an asset in helping an organization implement continuous monitoring and automation. With their expertise in security standards, industry best practices, and tools, a C3PAO can give an organization a comprehensive view of their security posture and help ensure its systems and applications remain secure.

Understand Security Risks Through a C3PAO Assessment

A C3PAO assessment is a comprehensive analysis of security risks created by third-party vendors. It involves evaluating the vendor’s systems and processes to identify potential vulnerabilities and areas of risk. A C3PAO assessment is not just limited to physical security, but also includes an evaluation of the vendor’s digital infrastructure, data security, and personnel security measures.

Through a C3PAO assessment, an organization can understand the security risks associated with its vendors better and identify corrective measures to reduce or mitigate these risks. The assessment helps organizations identify any potential weak points related to CMMC 2.0 in their vendor’s security measures, reducing the likelihood of a data breach and other security incidents caused by the vendor.

A C3PAO assessment can also help organizations understand the potential legal and financial implications of working with a certain vendor and allow them to make an informed decision about the partnership.

Additional Benefits of Working With a C3PAO

Working with a C3PAO provides several benefits for organizations seeking certification under CMMC 2.0 standards:

Expertise: A certified third-party assessor has extensive experience assessing cybersecurity programs across multiple industries and can provide valuable insight into best practices for achieving compliance with CMMC 2.0 standards.

Objectivity: An independent third-party assessor provides unbiased feedback on an organization’s security posture that can help identify areas where improvements are needed.

Cost Savings: Working with a certified third-party assessor can save time and money compared to hiring internal staff or consultants who may not have expertise in assessing cybersecurity programs.

Efficiency: A certified third-party assessor can quickly identify gaps in an organization’s security posture, helping to reduce time spent preparing for certification.

Peace of Mind: Having an independent third-party assessor review a DoD supplier’s cybersecurity program provides peace of mind, ensuring that organizations have taken all necessary steps toward achieving compliance with CMMC 2.0 standards.

How to Prepare for a Third-party CMMC 2.0 Assessment and Certification from a C3PAO

Preparing for a third-party CMMC 2.0 assessment and certification can be a daunting and complex task. It is important to take the time to understand the requirements of the assessment and certification process and to ensure that your organization is adequately prepared. You will have an easier time preparing for a CMMC 2.0 assessment and certification by ensuring the following: 

• It is essential to have a good understanding of the assessment framework and requirements. This includes having familiarization with the standards, criteria, and objectives that the assessor will be looking for. It is also important to have a clear understanding of the processes and procedures for the assessment. This includes ensuring that all relevant documents, such as policies, procedures, and evidence of compliance, are readily accessible and up to date.

• It is important to properly plan the assessment by scheduling sufficient time and resources to meet the requirements. This includes allocating enough personnel to facilitate the assessment, scheduling the assessment in a suitable location, and having the right equipment and materials.

• It is important to ensure that all relevant stakeholders are adequately prepared. This can involve comprehensive training sessions to ensure everyone understands the assessment requirements and is prepared to answer questions and demonstrate competence or compliance.

Preparing for a third-party CMMC 2.0 assessment and certification can take time and planning but is essential for successful completion. It is important to ensure that your organization is familiar with the standards and criteria, has allocated adequate resources and personnel, and has trained all relevant stakeholders.

Key Considerations for Selecting a C3PAO for CMMC 2.0 Compliance

When selecting a C3PAO, organizations should seriously consider the certifications, services, and experience that the C3PAO offers. Certifications of the C3PAO should be evaluated by the organization. The certifications should include the C3PAO’s formal training, expertise, and experience with the NIST National Initiative for Cybersecurity Education (NICE) Cybersecurity Workforce Framework (NIST SP 800-181). The certification should comply with NIST SP 800-171 and the Federal Information Security Management Act (FISMA).

The services that the C3PAO can provide should be considered, too. The C3PAO should be able to provide audit services, report writing services, and remediation advice to the organization. The C3PAO should also be able to provide risk assessments, threat intelligence, and recommendations to improve security. A C3PAO’s experience in security management should be evaluated. C3PAOs should have experience in developing and implementing security programs, policies, and procedures. They should have the ability to assess the organization’s security posture, identify gaps, and make recommendations. Further, the C3PAO should provide timely and accurate reports to the organization.

A C3PAO’s ability to work with other industry professionals must be evaluated as well. The C3PAO should be able to work with IT vendors, systems administrators, and other stakeholders to ensure the organization’s security posture is up to par. The C3PAO should also be able to effectively communicate with executive management and staff to discuss security issues and explain the organization’s security posture.

Finally, the C3PAO’s fee structure and customer service should be considered. In particular, beyond being cost effective, the C3PAO should have excellent customer service and be willing to communicate with the organization regularly.

Organizations need to carefully consider certifications, services, experience, and customer service when selecting a C3PAO. The C3PAO must have appropriate certifications, provide the necessary services, have the right experience, and provide excellent customer service. These considerations ensure that organizations select the most appropriate C3PAO.

How to Get Started With a C3PAO Assessment

Getting started on a C3PAO assessment can be done in three steps:

1. Prepare a plan on what the assessment will include and what the trajectory will look like for obtaining C3PAO certification.
2. Create a checklist of requirements for the assessment, including regulatory requirements and consideration of the organization’s operating environment.
3. Obtain a qualified C3PAO to validate the assessment. It is important to ensure that the assessor has the appropriate qualifications, experience, and knowledge for the C3PAO assessment.

After these steps, the organization must implement all the necessary processes, procedures, and controls for a successful assessment and to gain certification. This includes implementing a baseline of security controls, documenting the processes, and obtaining all the necessary documentation from the appropriate personnel. The C3PAO finally reviews the assessment, evaluates the documents and the controls, and verifies that the organization is compliant with the requirements and is prepared for certification. With these steps, organizations can be well on their way to gaining CMMC 2.0 certification.

Kiteworks Helps Organizations Streamline the C3PAO Assessment and Demonstrate CMMC 2.0 Level 2 Compliance

Because Kiteworks is FedRAMP Authorized, unlike many other solution options in the marketplace, it supports nearly 90% of CMMC Level 2 requirements out of the box.

As a result, Kiteworks makes it easier and faster for C3PAOs to certify DoD contractors for CMMC compliance. Using content-defined zero trust, Kiteworks protects sensitive communications of CUI and FCI content and includes secure process management to support the workflow and review of activities and user authentication to safeguard against malicious actors.

Schedule a custom demo tailored to see the Kiteworks platform in action and how it can accelerate your CMMC compliance journey today.

Additional Resources

• Blog A Roadmap for CMMC 2.0 Compliance for DoD Contractors
• Brief Kiteworks Secure Managed File Transfer (MFT)
• White Paper How to Secure Content Communications for CMMC 2.0
• Blog Post 12 Things Defense Industrial Base Suppliers Need to Know When Preparing for CMMC 2.0 Compliance
• White Paper CMMC 2.0 Compliance Mapping for Sensitive Content Communications