CMMC
DoD certification for DIB cybersecurity maturity levels
ISO 27018
Code of practice for PII protection in public clouds
Quick Verdict
CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI, while ISO 27018 provides voluntary privacy controls for cloud PII processors. Organizations adopt CMMC for contract eligibility; ISO 27018 for global trust and procurement acceleration.
CMMC
Cybersecurity Maturity Model Certification 2.0
Key Features
- Three cumulative levels aligned to FCI/CUI protection
- Third-party C3PAO and DIBCAC assessments for verification
- Direct mapping to 110 NIST SP 800-171 controls
- Supply chain flow-down and SPRS affirmation requirements
- POA&Ms with strict 180-day closure timelines
ISO 27018
ISO/IEC 27018:2025 Code of practice for PII in public clouds
Key Features
- Transparency on subprocessors and data processing locations
- Prohibits PII use for marketing without consent
- Requires breach notification to customers
- Adds 25-30 privacy controls to ISO 27001
- Supports data subject rights in cloud environments
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 model with three cumulative levels: Level 1 (basic FCI safeguards), Level 2 (NIST SP 800-171 for CUI), and Level 3 (NIST SP 800-172 enhancements against APTs). The approach emphasizes scoping, evidence-based assessments, and supply chain flow-down.
Key Components
- 14 domains (e.g., Access Control, Incident Response) with 17 Level 1, 110 Level 2, and 134 Level 3 practices.
- 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), reported to SPRS/eMASS; POA&Ms allowed with 180-day closures.
Why Organizations Use It
Mandatory for DoD contractors handling FCI/CUI to ensure contract eligibility, reduce breach risks, and gain competitive advantage. Enhances operational resilience, supply chain trust, and market access while mitigating IP theft and regulatory penalties.
Implementation Overview
Phased approach: scoping/gap analysis, remediation, assessment preparation, certification, sustainment. Applies to all DIB primes/subcontractors; complex for SMEs due to evidence requirements. Triennial recertification with annual affirmations.
ISO 27018 Details
What It Is
ISO/IEC 27018:2025 is an international code of practice extending ISO/IEC 27001 and ISO/IEC 27002 specifically for protecting personally identifiable information (PII) processed by public cloud service providers acting as PII processors. Its scope targets public cloud environments, using a risk-based, control-oriented methodology to address privacy challenges like multi-tenancy and cross-border data flows.
Key Components
- ~25–30 privacy-specific controls integrated into ISO 27001 Annex A themes (organizational, people, physical, technological)
- Core principles: consent/choice, purpose limitation, data minimization, accuracy, retention limits, security, transparency, accountability
- Assessed within ISO 27001 certification audits; no standalone certification
Why Organizations Use It
- Builds trust, accelerates procurement via Statement of Applicability
- Aligns with GDPR Article 28, HIPAA processor obligations
- Mitigates privacy risks, supports cyber insurance
- Differentiates CSPs in competitive markets
Implementation Overview
- Gap analysis on existing ISMS, update SoA and policies
- Implement transparency, breach notification, technical safeguards
- Applicable to CSPs globally, all sizes; third-party audits required
Key Differences
| Aspect | CMMC | ISO 27018 |
|---|---|---|
| Scope | Cybersecurity for DoD FCI/CUI in DIB | PII protection in public cloud processors |
| Industry | Defense contractors, US-focused DIB | Cloud service providers, global applicability |
| Nature | Mandatory DoD certification program | Voluntary code of practice extension |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | ISO 27001 audits with privacy controls |
| Penalties | Contract ineligibility, debarment risks | No legal penalties, certification loss |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and ISO 27018
CMMC FAQ
ISO 27018 FAQ
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