Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification for cybersecurity maturity in defense supply chain

    VS

    AEO

    Voluntary
    2008

    Global certification for low-risk supply chain security

    Quick Verdict

    CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI, while AEO is voluntary customs status for low-risk traders securing supply chains. DoD firms adopt CMMC for contract eligibility; global traders pursue AEO for faster clearance and fewer inspections.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Three tiered certification levels for FCI, CUI, APTs
    • C3PAO and DIBCAC third-party assessments for verification
    • Direct mapping to 110 NIST SP 800-171 controls
    • SPRS affirmations and eMASS reporting requirements
    • Flow-down mandates across DIB supply chains
    Customs Security

    AEO

    Authorized Economic Operator (AEO) Program

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Risk-based supply chain security across 13 criteria
    • Demonstrated customs compliance and infringement absence
    • Robust records management and audit trails
    • Financial solvency and viability assessments
    • Mutual Recognition Agreements for cross-border benefits

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    CMMC Details

    What It Is

    Cybersecurity Maturity Model Certification (CMMC) 2.0 is a DoD certification framework verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered, risk-based model with three levels: Level 1 for basic FCI safeguards, Level 2 for CUI via NIST SP 800-171, and Level 3 for APT defenses adding NIST SP 800-172.

    Key Components

    • 14 domains (e.g., Access Control, Incident Response) with 17 practices (Level 1), 110 (Level 2), plus 24 enhanced (Level 3).
    • Built on FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
    • Certification via self-assessments (Level 1/2), C3PAO (Level 2), or DIBCAC (Level 3), with POA&Ms limited to 180 days and SPRS/eMASS reporting.

    Why Organizations Use It

    Mandated for DoD contractors/subcontractors handling FCI/CUI, ensuring contract eligibility. Reduces breach risks, enhances supply chain trust, and provides competitive bidding advantages. Builds operational resilience and aligns with broader NIST frameworks.

    Implementation Overview

    Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Applies to all DIB sizes, from SMEs to primes. Requires SSPs, evidence collection, annual affirmations; timelines 12-18 months for Level 2.

    AEO Details

    What It Is

    Authorized Economic Operator (AEO) is a voluntary certification program established under the World Customs Organization (WCO) SAFE Framework of Standards. It designates compliant, low-risk businesses involved in international goods movement as trusted partners. The primary purpose is to secure supply chains while facilitating trade via risk-based customs controls and partnerships. Key approach includes self-assessment via harmonized SAQ (Criteria A-M), rigorous validation, and ongoing monitoring.

    Key Components

    • Four pillars: customs compliance, records/internal controls, financial solvency, supply chain security.
    • 13 SAQ criteria groups covering training, data security, cargo/premises/personnel security, partners, crisis management, continuous improvement.
    • Built on SAFE Framework; compliance model features initial validation, periodic re-validation, mutual recognition.

    Why Organizations Use It

    • Facilitation benefits: reduced inspections, priority clearance, cost savings (e.g., avoided exams).
    • MRAs enable cross-border advantages.
    • Enhances risk management, reputation, tender competitiveness; voluntary but strategic for trade efficiency.

    Implementation Overview

    • Phased: gap analysis, SOPs design, training, digital evidence/IT integration, mock audits.
    • Cross-functional project for supply chain actors; 6-12 months typical; requires site audits, continuous governance.

    Key Differences

    Scope

    CMMC
    Cybersecurity for FCI/CUI in DoD contracts
    AEO
    Supply chain security and customs compliance

    Industry

    CMMC
    Defense Industrial Base (DIB), US-focused
    AEO
    International trade, logistics, global supply chains

    Nature

    CMMC
    Mandatory certification for DoD contractors
    AEO
    Voluntary trusted trader status

    Testing

    CMMC
    Self-assess/C3PAO/DIBCAC every 3 years
    AEO
    Customs validation, periodic re-validation

    Penalties

    CMMC
    Contract ineligibility, debarment
    AEO
    Status suspension/revocation, lost benefits

    Frequently Asked Questions

    Common questions about CMMC and AEO

    CMMC FAQ

    AEO FAQ

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