How to Write an Effective System Security Plan (SSP): A Strategic Approach to CMMC Compliance

The System Security Plan (system security plan) plays a critical role in determining whether a defense contractor is ready to handle, share, and store controlled unclassified information (CUI). As a result, it’s a vital part of the Cybersecurity Maturity Model Certification (CMMC) compliance process.

Effective SSP preparation requires a comprehensive approach to documenting the security measures and practices your organization adopts to safeguard its information assets. Crafting the SSP for CMMC involves detailing specific security controls, assigning responsible roles, and delineating system boundaries.

Additionally, it’s essential to regularly update the SSP to reflect any changes in the system infrastructure or security posture. By meticulously addressing these areas, organizations can enhance their preparedness for CMMC assessments and ensure that they meet the rigorous standards set for securing CUI.

This comprehensive guide reveals why your SSP is far more than just documentation—it’s the strategic foundation that can make or break your CMMC certification efforts.

What is a System Security Plan (SSP)?

A System Security Plan is a formal document that provides a comprehensive overview of an organization’s security requirements and describes the controls in place or planned to meet those requirements. For defense contractors handling Controlled Unclassified Information (CUI), the SSP specifically documents how your organization implements the security requirements outlined in NIST 800-171.

The SSP is not merely a compliance checkbox; it serves as the authoritative record of your organization’s cybersecurity posture, detailing:

• The boundaries of your information system
• The security controls implemented within that system
• How those controls are implemented
• Who is responsible for maintaining security
• How your security program operates on a day-to-day basis

As the Department of Defense (DoD) strengthens its supply chain security through CMMC, your SSP transforms from a static document into a living roadmap of your security program.

Differences Between SSPs and Security Policies

While related, a System Security Plan (SSP) and organizational security policies serve distinct purposes.

Security policies are high-level documents establishing management’s intent, expectations, and overarching rules for security across the organization. They define the ‘what’ – for example, a policy might state, “Access to sensitive data repositories must be restricted based on the principle of least privilege.” Policies set the direction and governance framework.

In contrast, the system security plan is a detailed, system-specific document outlining the ‘how, where, when, and who’ of security control implementation for a particular information system handling CUI. It translates policy requirements into concrete actions within defined system boundaries. For instance, corresponding to the policy example above, the SSP would detail: “Access to the CUI File Share (\\SERVER01\CUI_Data) is controlled via Active Directory security groups. The ‘CUI_Users_ProjectX’ group, managed by IT Administrator Jane Smith, grants read/write access. Access requests require manager approval via Service Desk ticket (Procedure SD-015) and are reviewed quarterly by the Data Owner, Mark Lee.”

A common misconception is viewing the SSP as merely a collection of policies; in reality, it’s a comprehensive implementation plan that describes the security posture of a specific system, referencing policies but providing much deeper operational detail essential for demonstrating compliance, particularly for an SSP for CMMC assessment.

Why SSPs are Important

The importance of a well-crafted SSP extends far beyond mere compliance. Your SSP serves as a comprehensive risk management tool that provides a systematic approach to identifying, assessing, and managing security risks. By thoroughly documenting your security controls, you create visibility into potential vulnerabilities and establish a robust framework for addressing them before they can be exploited.

For your technical teams, the SSP functions as an authoritative implementation guide that directs the deployment and configuration of security controls across your environment. This guidance ensures consistency in your security implementation and helps prevent configuration drift that could introduce vulnerabilities. During CMMC assessments, this same document becomes your primary evidence demonstrating your organization’s implementation of required security practices to assessors.

Beyond its technical and compliance functions, your SSP also acts as a business continuity asset that helps ensure operational resilience by documenting security procedures that protect critical information and enable swift recovery from security incidents. Perhaps most importantly, the SSP serves as a communication bridge, providing a clear articulation of your security program that facilitates understanding between technical staff, management, and external assessors.

An inadequate SSP can lead to failed assessments, delayed certifications, lost contracts, and ultimately, financial losses. Conversely, a well-developed SSP accelerates your path to certification and provides lasting security benefits beyond compliance.

SSP Requirements Across CMMC Levels

Understanding which CMMC level requires an SSP is critical for compliance planning:

• CMMC Level 1: An SSP is not required for Level 1 certification. Organizations must implement 17 basic safeguarding practices, but formal documentation in an SSP format is not mandatory.
• CMMC Level 2: An SSP is required for Level 2 certification. Organizations must develop and maintain a comprehensive SSP that documents the implementation of 110 security practices derived from NIST SP 800-171.
• CMMC Level 3: An SSP is required for Level 3 certification. The SSP at this level must document the implementation of additional advanced security practices beyond Level 2 requirements.

For organizations seeking Level 2 or Level 3 certification, the SSP serves as the fundamental artifact that C3PAOs will evaluate during an assessment. It provides the roadmap that guides assessors through your cybersecurity implementation and demonstrates your understanding of security requirements.

During the assessment process, your SSP serves as the foundation for successful certification. Before assessors even arrive at your facility, they will thoroughly review your SSP to understand your environment and prepare their assessment approach, making this document their first impression of your security program. As the assessment progresses, assessors will methodically compare your documented controls against your actual implementation to verify alignment, using the SSP as their roadmap through your complex security landscape.

Any discrepancies discovered between your SSP and implemented controls will be flagged as potential gaps requiring remediation, potentially jeopardizing certification if significant or numerous. A clear, comprehensive SSP significantly streamlines this process, potentially reducing both assessment time and associated costs while demonstrating your organization’s security maturity. In cases where full compliance hasn’t yet been achieved, your SSP provides essential context for developing realistic and effective Plans of Action and Milestones (POA&M) that can satisfy assessor requirements.

For CMMC certification success, your SSP must be accurate, comprehensive, and reflective of your actual security practices—assessors will be verifying that “you do what you document, and document what you do.”

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

The NIST SP 800-171 Foundation for CMMC SSPs

The System Security Plan required for CMMC Level 2 and 3 originates directly from the requirements outlined in NIST 800-171, “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations.” This NIST standard forms the backbone of CMMC’s security requirements.

Specifically, CMMC Level 2 maps directly to the 110 security controls detailed in NIST SP 800-171. A core requirement within NIST SP 800-171 itself (Control 3.12.4, Security Assessment family) mandates that organizations “develop, document, and maintain a system security plan that describes system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.” Therefore, the SSP for CMMC is essentially the NIST SP 800-171 system security plan focused on CUI protection.

NIST SP 800-171 Appendix E provides suggested content and structure for this plan, outlining key sections like System Identification, System Environment of Operation, and Security Requirement Implementation. Organizations developing their SSP for CMMC should heavily leverage NIST SP 800-171 and associated NIST resources (like NIST Handbook 162 for assessment procedures) to ensure all required elements are addressed comprehensively, as assessors will evaluate the SSP against these foundational standards.

Key Components of an Effective SSP

A compliant and useful SSP contains several essential elements that work together to present a comprehensive view of your security program. At its foundation, the SSP must include thorough system identification and boundary definition that clearly articulates the information system’s purpose, boundaries, and interconnections. This foundational section should incorporate detailed network diagrams, data flow diagrams, and system inventories that precisely delineate CUI environments from general business systems.

The heart of your SSP lies in its security control implementation statements. For each applicable NIST 800-171 control, your SSP should provide detailed descriptions explaining how the control is implemented, where it is implemented across your components or systems, who bears responsibility for maintaining the control, when control activities are performed, and what specific evidence demonstrates compliance. These implementation statements form the core content that assessors will evaluate during certification.

Your SSP must also document the organizational structure supporting your security program by detailing specific security roles, responsibilities, and contact information for key personnel. This should be complemented by comprehensive information system architecture descriptions covering hardware, software, network architecture, security domains, and trust relationships that define your environment.

The operational context of your system is equally important. Your SSP should thoroughly document the technical, physical, and personnel security environment within which the system operates, along with specific details on how CUI is identified, marked, handled, stored, processed, and transmitted throughout its lifecycle. This data security section proves particularly critical for CMMC assessments focused on CUI protection.

To demonstrate ongoing security commitment, include a detailed continuous monitoring strategy that outlines your approach to ongoing control assessment, vulnerability management, and security status reporting. Finally, reference all supporting documentation such as policies, procedures, and technical configurations that substantiate your control implementation claims and provide additional context for assessors.

The SSP should be organized to facilitate both management oversight and technical implementation, serving as a single source of truth for your cybersecurity program.

SSP Assessment Process and Criteria

During a CMMC assessment, the CMMC Third-Party Assessment Organization (C3PAO) rigorously evaluates the System Security Plan (SSP).

The process typically begins with a pre-assessment document review where assessors scrutinize the SSP for completeness, clarity, and apparent accuracy. They are specifically looking for: detailed descriptions for each applicable CMMC practice (derived from NIST SP 800-171 for Level 2), a clearly defined system boundary, accurate depiction of the system environment, identification of responsible personnel, and references to supporting evidence (policies, procedures, configurations).

Common reasons SSPs fail assessment include vague or generic control descriptions, missing practice documentation, outdated information that doesn’t match the current environment, poorly defined or inaccurate system boundaries, lack of referenced evidence, or an over-reliance on immature Plans of Action & Milestones (POA&Ms).

Following the document review, during the assessment itself (often involving on-site or remote components), assessors validate the SSP’s claims through interviews with key personnel (IT staff, management, users) and technical verification methods like examining system configurations, observing processes, reviewing logs, and inspecting physical security measures. They are confirming that the organization “does what it documents.”

A certification-ready system security plan is current, comprehensive, highly detailed, accurately reflects the implemented controls, directly references supporting evidence, and aligns perfectly with the operational reality verified during the assessment interviews and technical checks.

Top 10 Best Practices for Writing an Effective SSP

Based on our experience assessing hundreds of defense contractors, we’ve identified these critical best practices for developing an SSP that will support your CMMC certification efforts:

1. Define Clear System Boundaries

Precisely delineate what is in-scope versus out-of-scope for your CUI environment. Many assessment failures stem from ambiguous boundaries that leave assessors uncertain about where controls should be applied.

Recommended Approach: Create detailed network diagrams that precisely identify your CUI environment boundaries with clear visual distinctions for all entry and exit points, security domains, and trust relationships. Employ consistent visual coding, such as color schemes, to distinguish CUI environments from general business systems, making boundaries immediately apparent to both your team and assessors. These diagrams should be complemented by explicit text descriptions that leave no room for ambiguity about what systems fall within scope for CMMC controls. Update these boundary definitions whenever your environment changes to ensure continued accuracy throughout your certification journey.

Pitfall to Avoid: Don’t make your boundary so broad that it encompasses systems unnecessary for CUI processing, as this expands your compliance scope unnecessarily.

2. Provide Detailed Control Implementation Descriptions

Generic statements like “we use encryption” or “we have firewalls” are insufficient. Assessors need specific details about how each control is implemented in your environment.

Recommended Approach: For each control, develop comprehensive descriptions that articulate precisely how the control objectives are met within your specific environment. Detail the exact technologies or processes employed, including vendor names, versions, and specific configurations that satisfy the security requirements. Explain how each solution is configured and managed to address the specific control objective, going beyond mere technology mentions to describe operational processes. Document how these controls are monitored for effectiveness and how often they undergo review to ensure continued compliance. Include sufficient technical specificity that another security professional could understand and validate your implementation without requiring additional explanation.

Example: For Access Control (AC.L2-3.1.1), instead of stating “We limit system access to authorized users,” provide details like: “Access to CUI systems requires multi-factor authentication using Yubikey hardware tokens in conjunction with complex passwords (minimum 12 characters). All access requests follow the Access Management Procedure (AMP-201) requiring documented management approval and quarterly review.”

3. Include Supporting Documentation and Evidence References

Your SSP should reference the specific policies, procedures, and evidence that support each control implementation.

Recommended Approach: Develop a comprehensive referencing system that creates clear connections between your SSP and all supporting documentation. For each control implementation statement, include precise references to relevant formal policy documents with specific document IDs and section numbers that authorize the control. Reference the detailed operational procedures that implement each policy requirement, ensuring traceability from high-level governance to day-to-day practices. Include citations to applicable technical standards or security baselines that guide implementation decisions. Document the specific locations where supporting evidence can be found, creating an evidence map that facilitates efficient assessment without embedding sensitive data in the SSP itself. This reference architecture ensures that your SSP serves as an effective navigation tool through your broader security documentation ecosystem.

4. Address POA&Ms Properly

No organization implements every control perfectly from day one. Plans of Action and Milestones (POA&Ms) document your approach to addressing identified gaps.

Recommended Approach: Develop a structured approach to documenting compliance gaps that demonstrates your commitment to continuous improvement. For each identified gap, create a POA&M entry that explicitly references the specific control requirement not fully implemented, using consistent identifiers that align with your SSP structure. Provide a detailed description of the current state that clearly articulates the precise nature of the compliance gap without minimizing its significance. Document comprehensive remediation plans with specific technical and procedural actions that will fully address the gap, broken into logical milestones. Assign clear responsibility for implementation to individuals with appropriate authority and technical capability. Establish realistic timelines that reflect both the risk level of the gap and the complexity of remediation, demonstrating urgency for high-risk items while acknowledging implementation constraints.

Critical Insight: While POA&Ms are allowed, they should address a minority of controls. Excessive POA&Ms indicate a security program that isn’t mature enough for certification.

5. Maintain Consistent Formatting and Organization

A well-organized SSP facilitates both development and assessment processes.

Recommended Approach: Implement a standardized documentation framework that enhances navigation and comprehension of your security controls. Adopt a consistent control description format that presents each security requirement in the same structural pattern, enabling assessors to quickly locate specific information across multiple controls. Utilize a numbering system that directly aligns with NIST 800-171 control identifiers, creating immediate traceability between requirements and implementations. Develop a comprehensive table of contents with hierarchical organization and hyperlinks that enable efficient navigation through your document. Employ appendices for supplementary information that provides important context without disrupting the main document flow. Consider visual elements like tables, diagrams, and consistent formatting to improve readability and highlight key information, making your SSP both technically precise and accessible to various stakeholders.

Tool Recommendation: Consider using NIST’s free SSP template as a starting point, customizing it to your organization’s needs.

6. Update Regularly to Reflect System Changes

Your SSP is a living document that must evolve as your systems and security controls change.

Recommended Approach: Establish a formal change management process specifically for maintaining SSP accuracy throughout your security program’s evolution. Implement documented review procedures that automatically trigger SSP evaluations after significant system changes, ensuring technical documentation remains aligned with actual implementation. Conduct comprehensive quarterly reviews at minimum to identify any gradual changes that might otherwise go undocumented. Maintain detailed documentation of all review activities and approvals, creating an audit trail of SSP maintenance that demonstrates ongoing governance. Implement robust version control for both the SSP and all supporting documents to provide a clear historical record of how security controls have evolved over time. This disciplined approach to SSP maintenance ensures that your compliance documentation continuously reflects your current environment rather than becoming an increasingly inaccurate snapshot of past practices.

Pitfall to Avoid: An outdated SSP that doesn’t reflect your current environment will undermine assessment success and could lead to security vulnerabilities.

7. Involve Cross-Functional Stakeholders

Security controls span technical, physical, and administrative domains, requiring input from across your organization.

Recommended Approach: Create a multidisciplinary SSP development team that brings together expertise from across your organization’s operational landscape. Include dedicated IT security personnel who understand control objectives and technical implementations alongside system administrators who manage daily operations of critical systems. Engage network engineers who can accurately document connectivity and boundary controls, complemented by HR representatives who can address personnel security requirements. Incorporate facilities management to address physical security controls and legal/compliance experts to ensure regulatory alignment. Secure executive sponsorship that provides both authority and resources for comprehensive SSP development. This diverse team ensures that your SSP addresses security controls holistically across all domains rather than focusing exclusively on technical controls while neglecting equally important administrative and physical safeguards.

Best Practice: Conduct collaborative workshops to gather input from relevant stakeholders when developing control descriptions.

8. Align with NIST 800-171 Control Families

Organize your SSP to mirror the structure of NIST 800-171, making it easier for assessors to verify compliance.

Recommended Approach: Structure your SSP according to the logical organization of the NIST 800-171 framework, which groups related controls into 14 cohesive families covering the complete spectrum of cybersecurity requirements. Begin with Access Control fundamentals that restrict system access to authorized users and transactions, followed by Awareness and Training controls that ensure personnel understand their security responsibilities. Continue with Audit and Accountability measures that create transparency through monitoring and review, alongside Configuration Management practices that establish and maintain system integrity. Address Identification and Authentication requirements for verifying user identities, then document Incident Response procedures for security events. Include Maintenance controls for system upkeep, Media Protection for information handling, Personnel Security for workforce assurance, and Physical Protection for facility safeguards. Complete your coverage with Risk Assessment processes, Security Assessment practices, System and Communications Protection mechanisms, and System and Information Integrity safeguards. This comprehensive structure ensures methodical coverage of all security domains while facilitating efficient assessment by aligning perfectly with the evaluation framework used by C3PAOs.

Critical Insight: This alignment simplifies the mapping between your SSP and assessment criteria, streamlining the certification process.

9. Address Supply Chain Considerations

CMMC emphasizes securing the entire defense supply chain, including your relationships with vendors and service providers.

Recommended Approach: Develop a comprehensive supply chain security strategy that addresses the extended security boundaries created by your external partnerships. Document in detail how third-party providers directly support specific security controls, mapping these relationships to individual CMMC requirements to demonstrate complete coverage. Establish and document clear security requirements for all vendors who handle or process CUI, including contractual obligations and verification mechanisms. Define precise responsibility boundaries for shared controls, clearly articulating which organization maintains responsibility for implementation, monitoring, and reporting for each security aspect. Implement and document robust monitoring and oversight procedures for verifying ongoing vendor compliance, including regular assessments, evidence collection, and remediation tracking. This detailed approach to supply chain documentation demonstrates to assessors that you understand and actively manage the complex security implications of your external relationships.

Pitfall to Avoid: Don’t assume that using a cloud service provider automatically transfers security responsibility away from your organization—you must document how you ensure the provider’s controls meet CMMC requirements.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

10. Document Exception Justifications

Some controls may not apply to your specific environment, but you must justify these exceptions rather than simply marking them “Not Applicable.”

Recommended Approach: Develop thorough, evidence-based justifications for any controls that genuinely do not apply to your specific environment. For each exception, provide detailed documentation that begins with a precise citation of the specific control requirement being exempted, ensuring clarity about what exactly is being excluded. Present a comprehensive explanation of why the control does not apply to your environment, grounded in technical architecture, business processes, or system capabilities rather than implementation difficulty. Document any compensating controls that mitigate the risks the original control was designed to address, demonstrating that security objectives are still being met through alternative means. Include formal approval evidence showing that exceptions have been reviewed and authorized by appropriate security governance authorities within your organization. This rigorous approach to exceptions demonstrates security maturity by showing that exclusions result from thoughtful analysis rather than avoidance of difficult controls.

Critical Insight: Exceptions should be rare and thoroughly justified. Assessors will scrutinize exception justifications closely.

SSP Templates and Resources

Several resources are available to help organizations develop their System Security Plan (SSP) for CMMC compliance.

NIST SP 800-171 Appendix E provides an official, though high-level, template structure that outlines the expected sections of an SSP. While valuable as a starting point, this NIST template requires significant customization. Avoid the pitfall of using generic content; your SSP must accurately reflect your specific system boundary, technologies, configurations, policies, and procedures. A generic SSP will not pass a CMMC assessment.

To illustrate the necessary detail, consider a section for CMMC practice AC.L2-3.1.5 (Prevent non-privileged users from executing privileged functions): “Execution of privileged functions (e.g., system configuration changes, software installation) is restricted to personnel within the ‘Domain Admins’ and ‘Server Operators’ Active Directory groups. Standard user accounts lack administrative rights on workstations and servers within the CUI boundary. User Account Control (UAC) is enabled on all Windows endpoints per baseline configuration [Config-Std-Win10-v2.1]. Privileged access attempts are logged centrally to [SIEM Tool Name] and reviewed per [Log Review Procedure ID].”

For managing SSP development and maintenance, options range from using customized word processing templates and spreadsheets (suitable for less complex environments, but require manual tracking) to dedicated Governance, Risk, and Compliance (GRC) software platforms. GRC tools (often paid solutions) offer features like automated control mapping, version control, evidence management, POA&M tracking, and reporting, which can be highly beneficial for larger or more complex organizations aiming for an efficient SSP for CMMC process. Free resources like NIST publications remain essential references regardless of the tools used.

How Kiteworks Provides SSP Documentation Support

A well-crafted System Security Plan is the cornerstone of successful CMMC certification. It transforms compliance from a daunting challenge into a structured process with clear milestones and responsibilities.

Remember that your SSP is more than just documentation; it’s a strategic asset that enables your organization to:

• Systematically implement required security controls
• Demonstrate compliance to assessors
• Identify and address security gaps
• Establish a foundation for continuous security improvement

By following the best practices outlined in this guide and leveraging purpose-built solutions like Kiteworks, you can develop an SSP that not only supports your CMMC certification goals but also enhances your overall security posture. Kiteworks helps organizations document their compliance for SSP development, including:

• Control Implementation Evidence: Kiteworks provides configurable security reports and audit logs that serve as direct evidence for control implementation.
• Policy Enforcement Documentation: The platform’s policy enforcement capabilities ensure and document consistent application of security controls across CUI processing.
• System Boundary Definition: Kiteworks helps establish clear boundaries for CUI environments through secure content communication channels.
• Risk Assessment Support: The platform’s security analytics help identify and document potential vulnerabilities for risk assessment documentation.

Kiteworks has also developed CMMC-focused capabilities to streamline compliance, including:

• CMMC Control Mapping: Kiteworks provides detailed documentation mapping its features to specific CMMC Level 2 controls, simplifying SSP development.
• CUI Handling Workflows: The platform includes preconfigured workflows designed specifically for compliant CUI handling.
• Secure Collaboration: Kiteworks enables secure collaboration with external partners without compromising CMMC compliance.
• Continuous Monitoring: Built-in security monitoring tools support continuous assessment of security control effectiveness.

By implementing Kiteworks as part of your CMMC compliance strategy, you gain both the technical controls needed for certification and the documentation support to develop a comprehensive SSP.

Kiteworks Supports CMMC 2.0 Compliance

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP, managed file transfer, and next-generation digital rights management solution so organizations control, protect, and track every file as it enters and exits the organization.

Kiteworks supports nearly 90% of CMMC 2.0 Level 2 compliance controls out of the box. As a result, DoD contractors and subcontractors can accelerate their CMMC 2.0 Level 2 accreditation process by ensuring they have the right sensitive content communications platform in place.

Kiteworks enables rapid CMMC 2.0 compliance with core capabilities and features including:

• Certification with key U.S. government compliance standards and requirements, including SSAE-16/SOC 2, NIST SP 800-171, and NIST SP 800-172
• FIPS 140-2 Level 1 validation
• FedRAMP authorized for Moderate Impact Level CUI
• AES 256-bit encryption for data at rest, TLS 1.2 for data in transit, and sole encryption key ownership

To learn more about Kiteworks, schedule a custom demo today.

System Security Plan FAQs
1. How long should a system security plan be?
There’s no prescribed page count for a system security plan. The length depends entirely on the complexity of the information system, the number of applicable controls (e.g., 110 for CMMC Level 2), and the level of detail needed to accurately describe implementation. Clarity, completeness, and accuracy are far more important than length. A comprehensive SSP for CMMC could easily range from 50 to several hundred pages.
2. How often should an SSP be updated?
The system security plan is a living document. NIST 800-171 requires it to be reviewed and updated at least annually, or whenever significant changes occur to the system, its environment of operation, security controls, or personnel. For CMMC, keeping the SSP current is crucial for maintaining certification.
3. What happens if CMMC assessors find discrepancies between the SSP and the actual implementation?
Assessors verify that what’s documented in the system security plan matches reality. Discrepancies are flagged as findings or gaps. Minor discrepancies might be addressed during the assessment, but significant deviations (e.g., a control documented as implemented is actually missing or misconfigured) can lead to assessment failure or require detailed entries in a Plan of Action & Milestones (POA&M), potentially delaying CMMC certification.
4. Can organizations include cloud services (e.g., IaaS, PaaS, SaaS like Microsoft 365 GCC High) in our SSP for CMMC?
Absolutely. If cloud services are part of the system processing, storing, or transmitting CUI, they must be included within the defined system boundary in your system security plan. You must clearly document the shared responsibility model, detailing which controls are fully or partially inherited from the Cloud Service Provider (CSP) and which are the organization’s responsibility. Evidence of the CSP’s compliance (e.g., FedRAMP authorization, SOC reports) should be referenced.
5. How do organizations properly document inherited security controls in the SSP?
For controls inherited from third parties (like CSPs or managed service providers), identify the specific control and the provider in your system security plan. Reference the provider’s compliance documentation (e.g., FedRAMP System Security Plan, Customer Responsibility Matrix). Crucially, describe how your organization verifies that the inherited control meets the CMMC requirement and how you manage your responsibilities within the shared model. Simply stating a control is inherited is insufficient; you must demonstrate due diligence.

Additional Resources

• Blog Post CMMC Compliance for Small Businesses: Challenges and Solutions
• Blog Post If You Need to Comply With CMMC 2.0, Here Is Your Complete CMMC Compliance Checklist
• Blog Post CMMC Audit Requirements: What Assessors Need to See When Gauging Your CMMC Readiness
• Guide CMMC 2.0 Compliance Mapping for Sensitive Content Communications
• Blog Post 12 Things Defense Industrial Base Suppliers Need to Know When Preparing for CMMC 2.0 Compliance