Everything You Need to Know About CMMC Third Party Assessor Organizations (C3PAO)

The Cybersecurity Maturity Model Certification (CMMC) is a cybersecurity framework aimed at bolstering the cybersecurity posture of the Defense Industrial Base (DIB). The CMMC framework is a United States Department of Defense (DoD) initiative to ensure that contractors in the DIB supply chain secure their information systems against cyber threats. The CMMC Third Party Assessor Organization (C3PAO) plays a critical role in the CMMC certification process by providing assessments and certification services to contractors. In this article, we will discuss everything you need to know about the CMMC Third Party Assessor Organization.

What Is CMMC?

CMMC is a unified cybersecurity standard that combines various cybersecurity practices, standards, and procedures to provide a unified approach to cybersecurity. CMMC was developed to protect controlled unclassified information (CUI) and federal contract information (FCI) from cyberattacks.

Who Needs to Comply With CMMC Requirements?

All contractors that work with the DoD need to comply with CMMC requirements. CMMC 2.0 has three levels, with each level indicating a different level of cybersecurity maturity. Contractors must achieve the appropriate level of CMMC certification to be eligible for contracts with the DoD. The level of CMMC certification required for a particular contract will depend on the type of information the contractor handles.

What Is a C3PAO?

A C3PAO is a Third Party Assessor Organization that has been authorized by the CMMC Accreditation Body (CMMC-AB) to conduct CMMC assessments. C3PAOs are independent organizations that provide assessment services to contractors. They play a critical role in the CMMC certification process by ensuring that contractors meet the required cybersecurity standards.

What Is the Role of a C3PAO in CMMC Compliance?

A C3PAO is essential for contractors that want to achieve CMMC certification. C3PAOs are responsible for conducting assessments and certifying contractors under the CMMC framework. C3PAOs are third-party organizations that are authorized by the CMMC Accreditation Body (CMMC-AB) to conduct CMMC assessments. These organizations must be certified by the CMMC-AB to provide assessment services. C3PAOs play a crucial role in the CMMC compliance process by ensuring that contractors meet the cybersecurity requirements set by the DoD.

What Is the Process of Selecting a C3PAO?

Contractors can select a C3PAO from a list of certified organizations provided by the CMMC-AB. Contractors should consider several factors when selecting a C3PAO, including the organization’s experience, expertise, and cost. It is also essential to ensure that the C3PAO is licensed and certified by the CMMC-AB.

How Can an Organization Become a CMMC C3PAO?

Becoming a CMMC C3PAO involves several phases that require compliance with specific requirements. The phases include:

1. CMMC C3PAO Candidacy

Phase One is the Candidacy phase, which includes several steps that a company must fulfill to be considered a 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.

2. CMMC C3PAO Approval

Phase Two is the Approval phase, which requires the company to undergo an organizational background check by Dun & Bradstreet, hold a CMMC-related registration or certification, and be 100% U.S. citizen owned, or undergo a Foreign Ownership, Control, or Influence (FOCI) background investigation. Additionally, becoming CMMC Level 3 compliant can involve significant costs and expansion of the organization’s cybersecurity program.

3. CMMC C3PAO Authorization

Phase Three is the Authorization phase, which requires the company 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 company to be ISO 17020 Certified within 27 months from the date of registration.

Becoming a CMMC C3PAO can be a substantial investment, but it can pay off in the long run. The costs of becoming a C3PAO, for example, can be significant, including expenses for insurance, certifications, assessments, and personnel. However, the CMMC program’s rollout will create opportunities for C3PAOs to participate in the emerging ecosystem of CMMC compliance services. Furthermore, it can help organizations ensure that their sensitive information is protected from cyberattacks and data breaches.

What Are the Eligibility Criteria for C3PAO Certification?

To be eligible for C3PAO certification, the applicant organization must be an existing Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) or ISO accredited audit and/or certification body. The organization must have been in operation for at least three years and have completed at least 10 CMMC assessments or equivalent cybersecurity assessments. The organization must employ a minimum of two Registered Practitioners or Certified Professionals who have completed the training and examination for the AB CMMC-ACP or AB CMMC-RP credentials. The organization must also have a documented Quality Management System that conforms to ISO/IEC 17021-1:2015 and the CMMC-AB requirements. The organization must then pass a CMMC-AB audit and on-site assessment, including a review of the Quality Management System and a demonstration of technical capability, before being authorized as a C3PAO.

How Do C3PAO Organizations Conduct Assessments?

The C3PAO assessment process involves several steps, including a pre-assessment, an assessment planning meeting, an on-site assessment, and a post-assessment review. During the pre-assessment, the C3PAO will review the contractor’s documentation and assess its cybersecurity posture. The assessment planning meeting is an opportunity for the C3PAO to discuss the assessment with the contractor and plan the on-site assessment. The on-site assessment involves an evaluation of the contractor’s cybersecurity practices and procedures. The post-assessment review is an opportunity for the C3PAO to review the assessment findings with the contractor.

How Long Does It Take for a C3PAO to Assess a Contractor?

C3PAO assessments can vary in length depending on the contractor’s size and complexity. Generally, assessments can take anywhere from a few days to a few weeks to complete. The C3PAO will work with the contractor to determine the appropriate length of the assessment.

What Are the Steps in the C3PAO’s Assessment Process?

The C3PAO’s assessment process consists of four steps:

1. Pre-assessment: The C3PAO reviews the contractor’s documentation and assesses its cybersecurity posture.
2. Assessment Planning Meeting: The C3PAO discusses the assessment with the contractor and plans the on-site assessment.
3. On-site Assessment: The C3PAO evaluates the contractor’s cybersecurity practices and procedures.
4. Post-assessment Review: The C3PAO reviews the assessment findings with the contractor.

What Is the Cost of a C3PAO Assessment?

The cost of a C3PAO assessment can vary depending upon several factors, including the CMMC level, complexity of the contractor’s unclassified network for the certification boundary, and market forces. Generally, C3PAOs determine their own assessment fees. However, the DoD will develop a new cost estimate associated with CMMC 2.0 to account for the changes made to the program, which will be published on the Federal Register as part of the rulemaking process.

Benefits of Working With a C3PAO

Working with a C3PAO provides several benefits for contractors. C3PAOs have expertise and experience in conducting cybersecurity assessments and can help contractors navigate the CMMC certification process. C3PAOs can also provide guidance on how to improve a contractor’s cybersecurity posture and help identify areas for improvement.

C3PAOs can help contractors achieve CMMC compliance by providing assessments and certification services. A C3PAO can evaluate a contractor’s cybersecurity posture and provide guidance on how to improve it to meet the required CMMC level. C3PAOs can also help contractors identify gaps in their cybersecurity practices and develop a plan to address these gaps.

What Expertise and Experience Do C3PAOs Offer?

C3PAOs have extensive experience and expertise in conducting cybersecurity assessments. They are trained to identify cybersecurity risks and can provide recommendations for mitigating those risks. C3PAOs also have knowledge of the CMMC framework and can help contractors navigate the certification process.

Frequently Asked Questions

What Is a CMMC C3PAO?

A CMMC C3PAO is a third-party organization that has been officially authorized by the Cybersecurity Maturity Model Certification Accreditation Body (CMMC-AB) to conduct assessments of companies seeking CMMC certification. These organizations are responsible for evaluating a company’s adherence to the CMMC framework and determining the appropriate level of certification for the company. C3PAOs must meet strict requirements and undergo a rigorous accreditation process before they can be authorized to conduct CMMC assessments.

Can a Contractor Fail a C3PAO Assessment?

Yes, a candidate organization can fail an assessment by a C3PAO if the organization does not meet the standards set by the Cybersecurity Maturity Model Certification (CMMC) framework. The C3PAO is responsible for evaluating the organization’s compliance with the requirements of the CMMC framework, and if the organization fails to meet the necessary standards, they may not receive the certification. It is important for organizations to carefully prepare and implement appropriate cybersecurity measures to ensure they meet the requirements of the CMMC framework and pass the assessment.

What Is the Difference Between a C3PAO and a Registered Practitioner (RP)?

A C3PAO is an organization that is authorized by the CMMC-AB to conduct CMMC assessments, while a Registered Practitioner (RP) is an individual who has completed CMMC training and is authorized to provide consulting services to help contractors prepare for CMMC certification.

How Long Does It Take to Achieve CMMC Certification With a C3PAO?

The length of time it takes to achieve CMMC certification with a C3PAO depends on several factors, including the contractor’s readiness, the complexity of the assessment, and the CMMC level being pursued. Generally, the process can take several months to complete.

Kiteworks Makes It Easier for C3PAOs to Certify DoD Contractors for CMMC 2.0 Level 2 Compliance

Because the Kiteworks Private Content Network is FedRAMP Authorized, unlike many other solution options in the marketplace, it supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box. This level of compliance is higher than competitive options.

As a result, Kiteworks makes it easier and faster for C3PAOs to certify DoD suppliers 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. As a result, Kiteworks makes it easier and faster for C3PAOs to certify DoD suppliers for CMMC compliance.

Kiteworks provides the ability to automate many of the systems and processes associated with meeting the CMMC requirements with audit trail reporting. This enables C3PAOs to complete their assessments of DoD suppliers, identifying any gaps that exist in CMMC practice controls.

DoD contractors and subcontractors seeking to compete for DoD business must achieve CMMC compliance. With the phased implementation beginning in May 2023, the time to start is now—and Kiteworks is the perfect starting point.

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

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