CMMC
DoD certification framework verifying DIB cybersecurity maturity
ISO 19600
International guidelines for compliance management systems
Quick Verdict
CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI via tiered assessments, while ISO 19600 provides voluntary guidelines for building scalable compliance management systems. DoD firms adopt CMMC for contracts; others use ISO 19600 for risk-based governance.
CMMC
Cybersecurity Maturity Model Certification (CMMC) 2.0
Key Features
- Three cumulative certification levels aligned to NIST/FAR
- Third-party C3PAO assessments for Level 2 CUI protection
- Government DIBCAC-exclusive assessments for Level 3 APT defenses
- Enclave scoping enables targeted compliance segmentation
- Mandatory flow-down requirements across DIB supply chains
ISO 19600
ISO 19600:2014 Compliance management systems — Guidelines
Key Features
- Risk-based CMS framework
- Good governance principles
- PDCA cycle structure
- Proportionality and scalability
- Integrates with other ISO standards
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 that verifies cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) across the Defense Industrial Base (DIB). Codified in 32 CFR Part 170, it employs a tiered, risk-based model with three cumulative levels drawn from FAR 52.204-21, NIST SP 800-171 Rev. 2 (110 controls), and NIST SP 800-172 enhancements.
Key Components
- **Three levelsLevel 1 (17 basic practices for FCI), Level 2 (110 NIST controls for CUI), Level 3 (24 additional for APTs).
- 14 domains (e.g., Access Control, Incident Response).
- **Assessment pathsSelf-assessments (SPRS), C3PAO (eMASS), DIBCAC for Level 3.
- Limited POA&Ms with 180-day closures; System Security Plans (SSPs).
Why Organizations Use It
- Mandatory for DoD contract eligibility and flow-down.
- Mitigates supply chain risks, reduces breaches, cuts costs.
- Provides bid competitiveness, operational resilience, prime trust.
Implementation Overview
Phased: governance, scoping/gaps, remediation, assessment, sustainment. Targets all DIB contractors/subcontractors; 3-year certifications with annual affirmations. Involves evidence collection, enclave segmentation for SMEs/enterprises.
ISO 19600 Details
What It Is
ISO 19600:2014 is International guidelines for compliance management systems (CMS). As a Type B guidance standard, it provides recommendations—not requirements—for establishing, implementing, evaluating, maintaining, and improving a risk-based CMS. Applicable to all organizations, it uses a high-level Annex SL structure with 10 clauses mirroring PDCA cycle.
Key Components
- Core principles: good governance, proportionality, transparency, sustainability.
- Pillars: context analysis, leadership commitment, planning (obligations/risks), support (resources/training), operation (controls), performance evaluation, improvement.
- No fixed controls; flexible benchmarking without certification.
Why Organizations Use It
- Mitigates legal penalties, operational disruptions, reputational damage.
- Drives efficiency (10-20% cost savings), market access, integrity culture.
- Enhances decision-making, future-proofs for ISO 37301 transition.
- Builds stakeholder trust across sectors like finance, manufacturing, healthcare.
Implementation Overview
Phased roadmap: leadership commitment, gap analysis, design/documentation, rollout, continuous improvement. Scalable for SMEs to multinationals; integrates with ISO 9001/14001. No formal certification; self-benchmarking via audits.
Key Differences
| Aspect | CMMC | ISO 19600 |
|---|---|---|
| Scope | Cybersecurity for FCI/CUI in DoD supply chain | General compliance management systems across obligations |
| Industry | Defense Industrial Base contractors/subcontractors | All industries/sectors/organization sizes globally |
| Nature | Mandatory certification for DoD contracts | Voluntary guidelines (non-certifiable) |
| Testing | Self-assess/C3PAO/DIBCAC every 3 years | Internal audits/management reviews (no certification) |
| Penalties | Contract ineligibility/debarment | No direct penalties (reputational/regulatory risks) |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and ISO 19600
CMMC FAQ
ISO 19600 FAQ
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