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CMMC Certification vs. CMMC Compliance: What’s the Difference and Which One Do You Need?

by Danielle Barbour updated April 18, 2024 CMMC Compliance

Reading Time: 10 minutes

As cyber threats evolve in complexity and frequency, the need for advanced cybersecurity measures increases. For companies in the defense industrial base (DIB), which handle sensitive government and military data, a high level of cybersecurity maturity ensures they are equipped with the necessary policies, technologies, and procedures to mitigate cyber risks that could jeopardize national security.

But because a cyberattack is never a matter of "if," but "when," cybersecurity maturity also signifies a company’s capability to respond swiftly and efficiently to incidents, minimizing potential damage. Thus, the maturity of an organization’s cybersecurity posture is not just about prevention but also about resilience and adaptability in an ever–evolving threat landscape. The Department of Defense (DoD) introduced the Cybersecurity Maturity Model Certification (CMMC) as a standard for assessing and enhancing the cybersecurity practices of its contractors. However, there is often confusion between the terms and concepts of "CMMC certification" and "CMMC compliance."

In this post, we’ll examine each concept, explain their importance, similarities and differences, whether you need one or the other (or both), and the paths to achieving them. If your business wishes to work with the DoD, it’s crucial you understand these terms up front so you can save valuable time and resources. You’ll also avoid running into trouble with the DoD, which could lead to non–compliance, contract cancellation, revenue loss, litigation, and more.

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

CMMC Certification Overview

CMMC certification is a formal recognition by the CMMC Accreditation Body (CMMC AB) that a defense contractor has met specific cybersecurity requirements at one of the CMMC 2.0’s three levels. Each level corresponds to an increasing degree of cyber hygiene, from basic cyber hygiene practices at Level 1 to advanced processes for reducing the risk from Advanced Persistent Threats (APTs) at Level 3.

CMMC certification validates that a defense contractor has met specific cybersecurity prerequisites at varying levels of stringency. The certification process for CMMC Level 1, considered foundational, focuses on safeguarding Federal Contract Information (FCI). It requires companies to implement basic cyber hygiene practices. Achieving Level 1 certification is relatively straightforward, involving adherence to 17 controls covering information protection.

The certification process for CMMC Level 2 and Level 3, by contrast, involves more complex requirements. CMMC Level 2 serves as a transition stage, demanding adherence to a subset of the security requirements specified in NIST SP 800–171 plus additional practices and processes, aiming at the protection of Controlled Unclassified Information (CUI). CMMC Level 3, on the other hand, requires a comprehensive implementation of all NIST 800-171 controls along with additional measures, marking a mature stance on cybersecurity readiness and resilience.

CMMC certification is designed not only to assess an organization’s cybersecurity posture but also to instill a culture of continuous cybersecurity improvement. It’s a formal, verifiable declaration that a company is capable of protecting sensitive Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) according to the DoD’s rigorous standards.

Why CMMC Certification Matters

CMMC certification is critical for many reasons. While it is a pre–requisite, obtaining this certification signifies an organization’s deep–seated dedication to upholding cybersecurity measures. It acknowledges the certified entity possesses not only the necessary technology but also the rigorous processes and procedures required to protect the United States’ defense supply chain against cyber threats and espionage efforts. Unless a primary contractor or their subcontractor achieves CMMC certification, they are effectively barred from competing for DoD contracts. Given the escalating complexity and sophistication of cyber threats in today’s business landscape, securing CMMC certification is more than a procedural hurdle; it represents a substantial advancement in an organization’s cybersecurity posture. This certification ensures that companies involved in the defense supply chain are equipped with a robust framework to mitigate risks, thereby contributing to the overall security of national defense information and technologies.

Which Organizations Need CMMC Certification?

Generally speaking, organizations that operate directly or indirectly with the Department of Defense (DoD) need some level of CMMC certification. This includes a wide range of companies, from prime contractors who deal directly with the DoD, down to subcontractors that might only play a minor role in the supply chain. The aim is to safeguard Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) against cyber threats, thereby strengthening the security posture of the defense industrial base.

KEY TAKEAWAYS

CMMC Certification vs. CMMC Compliance:
Certification involves formal recognition by the CMMC Accreditation Body (CMMC-AB), while compliance refers to aligning with the CMMC practices and processes without undergoing formal certification.
Importance of CMMC Certification:
CMMC certification is essential for organizations aiming to work with the DoD. Achieving certification demonstrates a company’s capability to protect CUI, contributing to national security.
Need for CMMC Compliance:
Compliance signifies adherence to cybersecurity best practices and prepares organizations for eventual certification. It helps identify and mitigate cybersecurity vulnerabilities, reducing the risk of data breaches.
CMMC Certification Process:
The path to CMMC certification involves identifying the appropriate certification level, undergoing a thorough evaluation by a C3PAO, and demonstrating compliance with the CMMC framework’s stringent standards.
Choosing Between Certification and Compliance:
Organizations must align their business goals with their CMMC objectives to determine whether certification or compliance is more suitable.

To clarify, while all entities dealing with the DoD must adhere to certain cybersecurity practices, not all need to be certified. The level of certification required varies based on the sensitivity of the information handled. For example, a defense contractor working on advanced weapons systems, dealing extensively with CUI, would likely need a higher level of CMMC certification compared to a supplier providing non–critical support services. Another scenario could involve an IT firm developing software for the DoD; such a company would also require CMMC certification to ensure the protection of sensitive data throughout the development and delivery processes.

CMMC Certification Process

The first step in CMMC certification involves identifying the appropriate certification level. For CMMC 2.0, there are three distinct levels delineated by the CMMC. These levels increase in stringency and sophistication, ranging from basic cyber hygiene practices at the initial level (Level 1), to highly advanced methodologies designed to thwart Advanced Persistent Threats (APTs) at the highest level (Level 3). Determining the appropriate CMMC level is based upon the degree of sensitivity of the information to be handled by the contractor and the specific risk considerations tied to their contractual obligations with the Department of Defense (DoD).

Not sure which CMMC level is right for your business? Learn the differences and make an educated decision.

Once the organization commits to a specific maturity level, it undergoes a thorough evaluation to ensure it’s cybersecurity practices and procedural implementations are in strict compliance with the stringent standards of cybersecurity excellence stipulated by the CMMC framework. This process not only involves adopting the necessary cybersecurity measures but also demonstrating a consistent and mature approach to managing and safeguarding sensitive federal information, thereby ensuring a robust defense against potential cyber threats.

Costs and Time Involved in Certification

The path to CMMC certification involves considerable financial and time investments. The cost varies significantly depending on the level of certification pursued, the size and complexity of the organization, and the maturity of its existing cybersecurity practices.

At a minimum, organizations can expect to invest in necessary cybersecurity upgrades, training for staff, and the assessment fee charged by the C3PAO. For small businesses that need to be CMMC certified, this process can be particularly daunting, necessitating careful planning and possibly external assistance to manage costs effectively.

Time is another critical factor in the certification process. From initial preparation to achieving certification, the timeline can span several months to over a year. Organizations must undergo a pre–assessment phase, implement required cybersecurity practices, and then proceed with the formal assessment by a C3PAO. A proactive approach, starting with a gap analysis and continuous improvement, can significantly streamline the certification journey.

CMMC Assessment Process

The CMMC certification process involves a thorough assessment of an organization’s cybersecurity program, policies, and practices. There are two types of assessment: a self–assessment and a certified assessment. A CMMC self-assessment refers to an organization’s internal review and adherence to CMMC requirements without external validation. This is typically suitable for companies that do not handle CUI or FCI but wish to align with CMMC best practices.

A certified assessment, by contrast, is conducted by a third–party assessment organization (C3PAOs) and validates an organization’s compliance with CMMC standards. These assessment organizations are accredited entities with the authority to assess the cybersecurity maturity of defense contractors and their adherence to the required cybersecurity standards. This certification is necessary for contractors and subcontractors directly involved with the Department of Defense (DoD) that aim to handle sensitive information. The assessment process involves a detailed examination of the organization’s compliance with the specific practices and processes outlined in the CMMC framework. During the assessment, the C3PAO evaluates the organization’s implementation of cybersecurity practices and processes across various maturity levels, ranging from basic cyber hygiene to advanced. This comprehensive review ensures that organizations meet the Department of Defense’s stringent requirements for protecting sensitive defense information on their networks.

When organizations successfully complete a certified assessment, they demonstrate their adherence to stringent cybersecurity requirements.

CMMC Compliance Overview

CMMC compliance, while closely related to CMMC certification, is a state of alignment with the CMMC practices and processes applicable to an organization’s specific level requirement. It’s the ongoing effort to meet the set cybersecurity standards, whether or not the formal certification process is immediately pursued. For organizations not yet ready to undergo CMMC certification, achieving and maintaining CMMC compliance is a critical step towards preparing for eventual certification.

In essence, CMMC compliance is about building and maintaining the cybersecurity infrastructure and culture necessary to protect sensitive defense–related information. It involves regular internal reviews, updates to cybersecurity practices, and employee training, ensuring that the organization remains in a state of preparedness for eventual certification.

Why CMMC Compliance Matters

Even for organizations not immediately seeking CMMC certification, CMMC compliance is of paramount importance. It signifies an organization’s commitment to safeguarding sensitive information, which is crucial not only for national security but also for an organization’s integrity and reputation. By achieving CMMC compliance, organizations can ensure that they are on the right track towards CMMC certification, making the process smoother and less resource–intensive when the time for certification comes.

In addition, achieving and maintaining CMMC compliance helps organizations in identifying and mitigating potential cybersecurity vulnerabilities, thereby reducing the risk of cyber incidents that could lead to a data breach. In this way, CMMC compliance is not only about meeting DoD requirements but also about instilling cybersecurity best practices that benefit the organization’s overall cybersecurity posture.

Strategies for Achieving CMMC Compliance

Achieving CMMC compliance, like CMMC certification, involves several steps. By taking a strategic approach to CMMC compliance, organizations can ensure alignment with CMMC standards and requirements and demonstrate their commitment to cybersecurity and readiness for obtaining CMMC certification. Let’s take a closer look at these steps.

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

Internal Assessments and Gap Analysis

The first step towards achieving CMMC compliance for many organizations involves conducting a thorough internal assessment and gap analysis. These activities allow a company to evaluate its current cybersecurity practices against the CMMC framework’s rigorous requirements. Identifying key gaps early is crucial for developing a roadmap to CMMC compliance. To facilitate, organizations often engage with CMMC–AB approved consultants or utilize self–assessment tools to gain a detailed understanding of where they stand in terms of cyber hygiene and what steps they need to take to align with their desired CMMC level.

Utilizing CMMC–AB Approved Tools

To help defense contractors achieve CMMC compliance, the CMMC Accreditation Body has endorsed a variety of tools designed to streamline the preparation process. These tools, ranging from documentation templates to comprehensive cybersecurity platforms, are tailored to meet the specific needs of organizations at different maturity levels. By leveraging these resources, businesses can significantly reduce the complexity and time required to achieve compliance, ensuring that they follow best practices endorsed by the CMMC–AB.

Maintaining CMMC Compliance

Achieving CMMC compliance is not a one–time event but a continuous process that requires ongoing vigilance. Regular CMMC compliance audits and continuous monitoring of cybersecurity practices are essential to maintaining compliance. These activities help identify potential vulnerabilities and ensure that the cybersecurity measures in place remain effective against evolving threats. Many organizations opt to conduct annual internal audits to ensure they consistently meet CMMC standards.

Maintaining CMMC compliance necessitates a commitment to ongoing improvement in cybersecurity excellence. This includes continuous security awareness training for employees, regular updates to cybersecurity policies and procedures, and the adoption of a proactive cybersecurity culture. By embedding these practices into the organizational fabric, businesses can ensure they not only achieve but sustain CMMC compliance and readiness for CMMC certification when the time comes.

CMMC Certification and CMMC Compliance: Which One is Right for You?

For defense contractors wondering whether to aim for CMMC certification or CMMC compliance, it’s important to understand the fundamental difference between the two. In essence, CMMC compliance serves as the foundation for CMMC certification. Organizations must first ensure they are compliant with the CMMC framework before they can pursue certification. This approach not only streamlines the CMMC certification process but also instills a culture of cybersecurity that benefits the organization beyond DoD contracts.

Choosing Between CMMC Certification and CMMC Compliance

Whether an organization requires CMMC certification or merely CMMC compliance depends largely on the organization’s objectives, namely how competitive the organization hopes to be in the DIB. DoD contracts will vary in sophistication and complexity, dictating different maturity levels and different compliance or certification requirements. Contracts with the DoD will explicitly state the required CMMC level, making certification non–negotiable for those wishing to participate. However, for subcontractors and companies aiming to gradually engage with DoD contracts, achieving and maintaining CMMC compliance is a critical step towards eventual certification.

It is imperative therefore that an organization choose a CMMC level to pursue. Aligning an organizations business goals with their CMMC objectives not only ensures compliance and certification readiness but also significantly enhances an organization’s cybersecurity resilience.

Kiteworks Helps Organizations Achieve CMMC Certification and Demonstrate CMMC Compliance

Pursuing CMMC certification versus CMMC compliance requires a clear understanding of both concepts, their importance, and the strategic path towards achieving them. While certification provides a formal acknowledgment of cybersecurity readiness, compliance represents an ongoing commitment to the protection of sensitive information. Defense contractors must assess their current cybersecurity posture, understand the requirements of the DoD contracts they wish to pursue, and align their cybersecurity efforts accordingly. By doing so, they not only meet the mandates of the CMMC but also contribute to the broader goal of enhancing the national defense supply chain’s security against cyber threats. Ultimately, the journey towards CMMC certification and compliance is a critical investment in the future of defense contracting and national security.

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 requirements 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.

With Kiteworks, DoD contractors and subcontractors unify their sensitive content communications into a dedicated Private Content Network, leveraging automated policy controls and tracking and cybersecurity protocols that align with CMMC 2.0 practices.

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

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more.

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

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