Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification framework for DIB cybersecurity maturity levels

    VS

    ISO/IEC 42001:2023

    Voluntary
    2023

    International standard for AI management systems

    Quick Verdict

    CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI via NIST controls and assessments, while ISO/IEC 42001:2023 offers voluntary AI governance frameworks. DoD firms adopt CMMC for contract eligibility; others pursue 42001 for ethical AI trust and compliance.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

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

    Key Features

    • Three cumulative levels tailored to FCI, CUI, APT risks
    • Third-party C3PAO and DIBCAC assessments beyond self-attestation
    • Direct mapping to 110 NIST 800-171 and 24 800-172 controls
    • Mandatory flow-down requirements to DoD subcontractors via DFARS
    • 180-day POA&M limits with annual SPRS/eMASS affirmations
    AI Management

    ISO/IEC 42001:2023

    ISO/IEC 42001:2023 Artificial Intelligence Management Systems

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

    Key Features

    • PDCA framework for AI lifecycle governance
    • Mandatory AI Impact Assessments for high-risk AI
    • Annex A with 38 AI-specific controls
    • Third-party and supply chain risk management
    • Seamless integration with ISO 27001/9001

    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, risk-based model with three cumulative levels: Level 1 for basic FCI safeguards, Level 2 for advanced CUI protection, and Level 3 for APT defenses.

    Key Components

    • 14 domains (e.g., Access Control, Incident Response) with 17 Level 1, 110 Level 2 (NIST SP 800-171), and 24 additional Level 3 (NIST SP 800-172) practices.
    • Built on FAR 52.204-21 and NIST standards.
    • Certification via self-assessments (Level 1/2), C3PAO (Level 2), or DIBCAC (Level 3), reported to SPRS/eMASS; limited POA&Ms with 180-day closures.

    Why Organizations Use It

    Mandated for DoD contractors/subcontractors handling FCI/CUI, ensuring contract eligibility and supply chain compliance. Reduces breach risks, enhances resilience, builds prime trust, and provides competitive bid advantages amid rising cyber threats.

    Implementation Overview

    Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Applies to all DIB sizes; complex for multi-tier chains. Requires SSP, evidence artifacts, annual affirmations; 12-18 months typical for Level 2.

    ISO/IEC 42001:2023 Details

    What It Is

    ISO/IEC 42001:2023 is the world's first international standard for Artificial Intelligence Management Systems (AIMS), a certifiable framework to establish, implement, maintain, and improve responsible AI governance. It uses Plan-Do-Check-Act (PDCA) methodology and High-Level Structure (HLS) for AI lifecycle risks like bias, transparency, and ethics.

    Key Components

    • Clauses 4-10: context, leadership, planning, support, operation, evaluation, improvement
    • Annex A: 38 AI-specific controls (e.g., data governance, third-party risks)
    • Annex B/C: implementation guidance and risk sources
    • Voluntary third-party certification model

    Why Organizations Use It

    Mitigates AI risks, ensures EU AI Act compliance, builds stakeholder trust, enables innovation, and provides competitive differentiation via certified ethical AI. Early adopters like Microsoft and UiPath gain procurement advantages and reputation boosts.

    Implementation Overview

    Phased gap analysis, AIIAs, training, audits; 6-12 months typical. Applies universally across sizes, sectors, roles (providers/users); integrates with ISO 27001/9001.

    Key Differences

    Scope

    CMMC
    Cybersecurity for FCI/CUI in DoD systems
    ISO/IEC 42001:2023
    AI management systems across lifecycle risks

    Industry

    CMMC
    Defense Industrial Base contractors globally
    ISO/IEC 42001:2023
    All industries, any AI role worldwide

    Nature

    CMMC
    Mandatory certification for DoD contracts
    ISO/IEC 42001:2023
    Voluntary international management standard

    Testing

    CMMC
    Self/C3PAO/DIBCAC assessments every 3 years
    ISO/IEC 42001:2023
    Third-party audits with PDCA monitoring

    Penalties

    CMMC
    Contract ineligibility and debarment
    ISO/IEC 42001:2023
    No legal penalties, loss of certification

    Frequently Asked Questions

    Common questions about CMMC and ISO/IEC 42001:2023

    CMMC FAQ

    ISO/IEC 42001:2023 FAQ

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