CMMC
DoD certification verifying cybersecurity for FCI and CUI
APRA CPS 234
Australian prudential standard for information security resilience.
Quick Verdict
CMMC certifies DoD contractors' NIST-aligned cybersecurity for FCI/CUI via tiered assessments, ensuring supply chain protection. APRA CPS 234 mandates Australian financial firms' information security governance with board accountability and rapid incident reporting for resilience.
CMMC
Cybersecurity Maturity Model Certification (CMMC) 2.0
Key Features
- Three cumulative levels for FCI, CUI, APT protection
- Third-party C3PAO certifications verifying Level 2 compliance
- DIBCAC-exclusive assessments for Level 3 enhancements
- Limited POA&Ms with mandatory 180-day closures
- Supply chain flow-down and SPRS affirmation requirements
APRA CPS 234
APRA Prudential Standard CPS 234 Information Security
Key Features
- Board ultimate responsibility for information security
- 72-hour APRA notification for material incidents
- Systematic independent testing of controls
- Third-party managed asset coverage
- Internal audit assurance requirements
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 program verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered model with three levels, mapping to FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172, emphasizing scoped assessments and evidence-based verification.
Key Components
- **Three cumulative levelsLevel 1 (17 basic practices), Level 2 (110 NIST controls), Level 3 (24 enhanced practices).
- 14 domains like Access Control, Incident Response, Risk Assessment.
- Assessment paths: self-assessments, C3PAO certifications, DIBCAC for Level 3.
- POA&Ms with 180-day limits; SPRS/eMASS reporting.
Why Organizations Use It
- Mandatory for DoD contracts, ensuring eligibility.
- Reduces breach risks, operational resilience.
- Competitive edge via certified status, supply chain trust.
- Lowers insurance, accelerates audits.
Implementation Overview
Phased approach: scoping, gap analysis, remediation, assessment, sustainment. Targets DIB contractors/subcontractors; complex for multi-tier chains. Requires SSP, evidence collection, triennial certifications, annual affirmations. (178 words)
APRA CPS 234 Details
What It Is
APRA Prudential Standard CPS 234 (Information Security) is a binding prudential regulation for Australian financial institutions regulated by APRA. Effective 1 July 2019, it requires entities to maintain information security capabilities commensurate with threats and vulnerabilities, minimizing impacts on confidentiality, integrity, and availability (CIA) of information assets, including those managed by third parties. It employs a risk-based, assurance-driven model emphasizing governance and evidence.
Key Components
- Board ultimate responsibility (para 13) and defined roles (para 14)
- Asset classification by criticality/sensitivity (para 20)
- Policy framework and commensurate controls (paras 18-22)
- Incident detection/response plans with annual testing (paras 23-26)
- Systematic testing (paras 27-31) and internal audit assurance (paras 32-34)
- APRA notifications: 72 hours for material incidents, 10 business days for weaknesses (paras 35-36) No fixed controls; built on CIA principles with third-party extensions.
Why Organizations Use It
- Mandatory for APRA-regulated entities (ADIs, insurers, super funds) to avoid enforcement
- Enhances cyber resilience, protects customers/depositors
- Manages third-party/supply-chain risks
- Builds stakeholder trust and operational continuity
Implementation Overview
Phased approach: gap analysis, governance/policies, asset inventory/classification, controls/testing, assurance. Applies Australia-wide to regulated entities of all sizes; ongoing APRA supervision, no certification but independent audits required. (178 words)
Key Differences
| Aspect | CMMC | APRA CPS 234 |
|---|---|---|
| Scope | NIST-based cybersecurity for FCI/CUI | Information security governance and resilience |
| Industry | US DoD defense contractors | Australian financial institutions |
| Nature | Tiered certification model, contract-mandated | Mandatory prudential standard, enforceable |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | Systematic independent testing, annual reviews |
| Penalties | Contract ineligibility, debarment | Regulatory sanctions, fines, remediation orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and APRA CPS 234
CMMC FAQ
APRA CPS 234 FAQ
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