Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification framework protecting FCI and CUI

    VS

    ISO 37001

    Voluntary
    2025

    International standard for anti-bribery management systems

    Quick Verdict

    CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI via tiered assessments, ensuring contract eligibility. ISO 37001 provides voluntary anti-bribery management for all organizations, mitigating corruption risks through risk-based controls and due diligence.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

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

    Key Features

    • Three cumulative maturity levels for tiered assurance
    • Third-party C3PAO assessments verify Level 2 compliance
    • Direct mapping to 110 NIST SP 800-171 controls
    • Mandatory certification for DoD FCI/CUI handling
    • Limited POA&Ms with strict 180-day closure
    Anti-Bribery/Compliance

    ISO 37001

    ISO 37001: Anti-Bribery Management Systems

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

    Key Features

    • Risk-based bribery risk assessment and controls
    • Third-party due diligence and monitoring requirements
    • Leadership commitment and compliance function
    • Financial and non-financial anti-bribery controls
    • PDCA cycle for continual improvement 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 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 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).

    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.
    • Assessment via self, C3PAO, or DIBCAC; reported to SPRS/eMASS; limited POA&Ms (180-day closure).

    Why Organizations Use It

    Mandated for DoD contracts, ensuring eligibility and flow-down compliance. Reduces breach risks, enhances supply chain trust, and provides competitive bidding advantages. Builds operational resilience and stakeholder confidence.

    Implementation Overview

    Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Targets DIB contractors (SMEs to primes); 12-18 months typical; requires SSP, evidence artifacts, annual affirmations. (178 words)

    ISO 37001 Details

    What It Is

    ISO 37001 is the international certifiable standard for Anti-Bribery Management Systems (ABMS). It provides requirements and guidance to prevent, detect, and respond to bribery risks. The scope covers direct/indirect bribery by/for the organization, personnel, and business associates across sectors/sizes. It follows the ISO Harmonized Structure (HS) and PDCA cycle for risk-based management.

    Key Components

    • **Clauses 4-10Context, leadership, planning, support, operation, evaluation, improvement.
    • Core controls: policy, risk assessment, due diligence, financial/non-financial controls, training, reporting.
    • Built on proportionality and continual improvement principles.
    • Optional third-party certification with audits.

    Why Organizations Use It

    • Mitigates legal risks (e.g., FCPA, UK Bribery Act).
    • Builds trust with stakeholders/investors.
    • Reduces compliance costs (up to 15%).
    • Enhances reputation and market access.

    Implementation Overview

    • Phased: gap analysis, risk assessment, controls, training, audits.
    • Applicable to all organizations globally.
    • Certification via Stage 1/2 audits, 3-year cycle.

    Key Differences

    Scope

    CMMC
    Cybersecurity for FCI/CUI protection
    ISO 37001
    Anti-bribery management system

    Industry

    CMMC
    DoD contractors and supply chain
    ISO 37001
    All sectors worldwide

    Nature

    CMMC
    Mandatory certification for contracts
    ISO 37001
    Voluntary certifiable standard

    Testing

    CMMC
    Self/C3PAO/DIBCAC assessments triennially
    ISO 37001
    Certification body audits, surveillance

    Penalties

    CMMC
    Contract ineligibility, debarment
    ISO 37001
    No direct penalties, certification loss

    Frequently Asked Questions

    Common questions about CMMC and ISO 37001

    CMMC FAQ

    ISO 37001 FAQ

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