What is the primary objective of **CMMC**?

**The primary objective of CMMC is to verify that Defense Industrial Base (DIB) organizations have implemented cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).** CMMC operationalizes requirements from FAR 52.204-21 (15 controls for Level 1), NIST SP 800-171 Rev. 2 (110 controls for Level 2), and NIST SP 800-172 (24 enhanced controls for Level 3), using a tiered model with defined assessment pathways to ensure supply chain protection against cyber threats.

Who is legally or professionally required to comply with **CMMC**?

**All DoD primes and subcontractors handling FCI or CUI in contract performance are required to comply with CMMC.** Contract solicitations specify the required level (1-3), with flow-down via DFARS 252.204-7021 mandating verification of subcontractor status in SPRS; this affects over 300,000 DIB entities across manufacturing, IT, and logistics, excluding only COTS items.

Does **CMMC** require an external audit or third-party certification?

**CMMC requires external audits or third-party certification depending on the level and contract.** Level 1 uses annual self-assessments; Level 2 offers self-assessments (OSA) every three years or C3PAO certification every three years; Level 3 mandates prerequisite Level 2 C3PAO plus triennial DIBCAC assessment, with results in eMASS and annual affirmations in SPRS.

How often should an assessment for **CMMC** be performed?

**CMMC assessments occur every three years for certification, with annual affirmations required across all levels.** Level 1: annual self-assessment and affirmation in SPRS; Level 2: triennial self or C3PAO plus annual affirmation; Level 3: triennial DIBCAC (post-Level 2 C3PAO) plus annual affirmations; certifications valid for three years, with POA&Ms closing in 180 days per 32 CFR §170.21.

What are the consequences of non-compliance with **CMMC**?

**Non-compliance with CMMC results in contract ineligibility and potential suspension or debarment.** Bids lacking required level certification or affirmation face disqualification; primes must withhold FCI/CUI from non-compliant subs, triggering remediation costs, DFARS clause violations, audits, supply chain disruptions, and financial/reputational losses.

An **CMMC** be mapped to other international frameworks?

**Yes, CMMC directly maps to NIST SP 800-171 Rev. 2 (Level 2, 110 controls) and NIST SP 800-172 (Level 3, 24 selections), with Level 1 from FAR 52.204-21.** The model organizes practices across 14 domains (e.g., AC, IA, SI) traceable to these NIST sources, enabling gap analysis and alignment without bespoke mappings.

What is the first step to begin implementing **CMMC**?

**The first step to implement CMMC is scoping per the DoD and CMMC Scoping Guides to identify FCI/CUI boundaries and determine the target level.** Map business processes, data flows, systems, and subcontractor interfaces to create an SSP skeleton, inventory enclaves, and conduct gap analysis against the applicable controls (15 for Level 1, 110 for Level 2, 134 for Level 3).

What is the primary objective of **AS9110C**?

**AS9110C's primary objective is to define quality management system requirements for aviation maintenance, repair, and overhaul (MRO) organizations to ensure consistent conformity of products and services to customer and regulatory requirements.** It builds on ISO 9001:2015's high-level structure, embedding aerospace-specific controls for configuration management, counterfeit parts prevention, human factors, traceability, and continuing airworthiness. This supports safe return-to-service, risk-based thinking across Clauses 4-10, and continual improvement via PDCA cycles.

Who is legally or professionally required to comply with **AS9110C**?

**AS9110C applies to MRO organizations performing maintenance on commercial, private, and military aircraft, including repair stations, component overhaul facilities, and OEM MRO divisions.** Compliance is professionally required for IAQG OASIS listing, customer contracts from airlines/OEMs, and alignment with FAA/EASA Part-145 regulations. It targets entities where aviation risks demand enhanced controls beyond ISO 9001, regardless of size.

Does **AS9110C** require an external audit or third-party certification?

**Yes, AS9110C requires third-party certification through accredited registrars following a two-stage external audit process.** Stage 1 reviews documentation and readiness; Stage 2 verifies effective implementation via on-site evidence of operational processes. Certification is valid for three years, with annual surveillance audits and recertification, ensuring QMS maturity including internal audits and management reviews.

How often should an assessment for **AS9110C** be performed?

**Internal audits for AS9110C must be performed at planned intervals based on process risk, with full cycles completed before certification and annually thereafter.** Management reviews occur at least yearly, using 3+ months of operational data. Higher-risk processes like maintenance planning and configuration control require more frequent audits, per Clause 9, to verify effectiveness and drive corrective actions.

What are the consequences of non-compliance with **AS9110C**?

**Non-compliance with AS9110C risks regulatory sanctions, loss of FAA/EASA Part-145 approvals, contract termination, and exclusion from IAQG OASIS and OEM supply chains.** It leads to potential fines, operational shutdowns, litigation from airworthiness failures, and reputational damage. Certification bodies may deny or revoke status if QMS lacks operational evidence, impacting market access.

An **AS9110C** be mapped to other international frameworks?

**Yes, AS9110C directly maps to ISO 9001:2015 via its shared Annex SL high-level structure across Clauses 4-10.** Correlation matrices align its aerospace additions (e.g., Clause 8 operational risks) to regulatory frameworks like FAA/EASA Part-145, enabling integrated QMS without duplication.

What is the first step to begin implementing **AS9110C**?

**The first step for AS9110C implementation is a formal gap analysis mapping existing processes to all clauses, including regulatory alignments.** Secure executive sponsorship, define QMS scope, and produce a prioritized gap register using IAQG tools, followed by a signed statement of work (SOW) for phased rollout.

CMMC vs AS9110C

Standards Comparison

CMMC

Mandatory

2021

DoD certification model for DIB cybersecurity maturity levels

AS9110C

Mandatory

2016

Aerospace QMS standard for aircraft maintenance organizations.

Quick Verdict

CMMC ensures cybersecurity for DoD contractors handling FCI/CUI via tiered certifications, while AS9110C provides quality management for aviation MROs emphasizing airworthiness and traceability. Organizations adopt CMMC for contract eligibility; AS9110C for safety, compliance, and market access.

Cybersecurity Maturity

CMMC

Cybersecurity Maturity Model Certification (CMMC) 2.0

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Three cumulative certification levels for FCI/CUI protection
Third-party C3PAO and DIBCAC assessments for verification
110 NIST SP 800-171 controls across 14 domains
Mandatory flow-down requirements to subcontractors
Limited POA&Ms with 180-day closure timelines

Quality Management

AS9110C

AS9110C Quality Management Systems for Aircraft Maintenance

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Risk-based thinking embedded in planning and operations
Configuration management for traceability and changes
Counterfeit parts prevention and detection controls
Maintenance release and airworthiness verification
Human factors integration in competence and audits

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 U.S. Department of Defense (DoD) certification program ensuring cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It employs a tiered, cumulative model with three levels, mapping to FAR 52.204-21, NIST SP 800-171 Rev 2 (110 controls), and NIST SP 800-172 (24 enhancements), using risk-aligned assessments.

Key Components

**LevelsLevel 1 (17 basic practices), Level 2 (110 controls), Level 3 (134 total).
14 domains (e.g., Access Control, Incident Response, Risk Assessment).
Assessment paths: self-assessments, C3PAO, DIBCAC; SPRS/eMASS reporting.
POA&Ms permitted with strict 180-day closures.

Why Organizations Use It

Mandatory for DoD contracts to secure eligibility and avoid debarment.
Mitigates supply chain risks, reduces breach costs.
Boosts bid competitiveness, operational resilience, insurance savings.
Enhances prime-subcontractor trust.

Implementation Overview

Phased: governance, scoping/gap analysis, remediation, assessment preparation, certification, sustainment. Targets DIB primes/subcontractors (SMEs to enterprises). Involves SSP development, evidence collection, training, annual affirmations, triennial recertification.

AS9110C Details

What It Is

AS9110C is the international quality management system (QMS) standard for aviation maintenance, repair, and overhaul (MRO) organizations. It builds on ISO 9001:2015 with aerospace-specific requirements for safety-critical processes. Primary purpose: ensure consistent delivery of airworthy products/services via risk-based thinking (RBT), PDCA cycles, and documented evidence.

Key Components

Core clauses (4-10) covering context, leadership, planning, support, operation, evaluation, improvement.
Aerospace additions: configuration management, counterfeit prevention, human factors, maintenance release.
Built on HLS; requires operational audits, management reviews.
Certification via accredited registrars with Stage 1/2 audits.

Why Organizations Use It

Meets customer/OEM contracts, regulatory alignment (FAA/EASA Part-145).
Mitigates safety risks, reduces rework/AOG events.
Enables market access, OASIS listing, supply-chain trust.
Drives efficiency, KPIs like TAT, NCR rates.

Implementation Overview

Phased: gap analysis, process design, pilot, audits, certification (6-12 months).
Applies to MROs globally; involves training, eQMS, RBT tools.
Requires 3+ months operational data pre-certification.

Key Differences

Aspect	CMMC	AS9110C
Scope	Cybersecurity for FCI/CUI protection	Quality management for aviation MRO
Industry	Defense Industrial Base contractors	Aerospace maintenance organizations
Nature	Tiered certification model mandatory for DoD	Voluntary QMS certification standard
Testing	Self-assess/C3PAO/DIBCAC every 3 years	Internal audits, registrar certification audits
Penalties	Contract ineligibility, debarment	Loss of certification, market exclusion

Scope

CMMC

Cybersecurity for FCI/CUI protection

AS9110C

Quality management for aviation MRO

Industry

CMMC

Defense Industrial Base contractors

AS9110C

Aerospace maintenance organizations

Nature

CMMC

Tiered certification model mandatory for DoD

AS9110C

Voluntary QMS certification standard

Testing

CMMC

Self-assess/C3PAO/DIBCAC every 3 years

AS9110C

Internal audits, registrar certification audits

Penalties

CMMC

Contract ineligibility, debarment

AS9110C

Loss of certification, market exclusion

Frequently Asked Questions

Common questions about CMMC and AS9110C

CMMC FAQ

AS9110C FAQ

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CMMC

AS9110C

Quick Verdict

CMMC

Key Features

AS9110C

Key Features

Detailed Analysis

CMMC Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

AS9110C Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

CMMC FAQ

What is the primary objective of CMMC?

Who is legally or professionally required to comply with CMMC?

Does CMMC require an external audit or third-party certification?

How often should an assessment for CMMC be performed?

What are the consequences of non-compliance with CMMC?

An CMMC be mapped to other international frameworks?

What is the first step to begin implementing CMMC?

AS9110C FAQ

What is the primary objective of AS9110C?

Who is legally or professionally required to comply with AS9110C?

Does AS9110C require an external audit or third-party certification?

How often should an assessment for AS9110C be performed?

What are the consequences of non-compliance with AS9110C?

An AS9110C be mapped to other international frameworks?

What is the first step to begin implementing AS9110C?

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