CMMC
DoD certification framework verifying cybersecurity for defense contractors
J-SOX
Japan's regulation for internal controls over financial reporting
Quick Verdict
CMMC certifies cybersecurity for DoD contractors protecting FCI/CUI via tiered assessments, while J-SOX mandates financial reporting controls for Japanese listed firms with annual management evaluation and auditor attestation. DoD suppliers adopt CMMC for contracts; listed companies use J-SOX for compliance and investor trust.
CMMC
Cybersecurity Maturity Model Certification (CMMC)
Key Features
- Three cumulative levels protecting FCI to APT threats
- Third-party C3PAO and DIBCAC assessments for verification
- Direct mapping to NIST 800-171 and 800-172 controls
- Mandatory flow-down across DIB supply chain subcontractors
- POA&Ms with strict 180-day closure requirements
J-SOX
Financial Instruments and Exchange Act (FIEA)
Key Features
- Management assessment of ICFR effectiveness
- Auditor attestation on management reports
- Explicit IT response component in framework
- Risk-based scoping for listed companies
- Principles-based control design flexibility
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) is a DoD certification program 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 24 additional Level 3 practices.
- Built on FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
- Assessment model: self-assessments (Levels 1/2), C3PAO (Level 2), DIBCAC (Level 3), with SPRS/eMASS reporting and limited POA&Ms.
Why Organizations Use It
Mandatory for DoD contractors/subcontractors; ensures contract eligibility, reduces supply chain risks, enhances resilience, and provides competitive advantage in bids. Builds stakeholder trust via verified maturity.
Implementation Overview
Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Applies to all DIB sizes; requires SSPs, evidence collection, annual affirmations. Typical for SMEs: 12 months, high effort.
J-SOX Details
What It Is
J-SOX, or Japan's Financial Instruments and Exchange Act (FIEA) internal control provisions, is a regulation mandating internal controls over financial reporting (ICFR) for listed companies. Enacted in 2006 and effective from April 2008, its primary purpose is ensuring reliable financial disclosures through management assessment and risk-based evaluation, covering consolidated entities and subsidiaries.
Key Components
- COSO framework augmented with IT response and asset preservation.
- Five core components plus IT: Control Environment, Risk Assessment, Control Activities, Information & Communication, Monitoring.
- Entity-level, process-level, and ITGC controls.
- Management evaluation with auditor attestation on report reliability.
Why Organizations Use It
- Mandatory for ~3,800 listed firms to restore investor confidence.
- Mitigates misstatement risks, reduces audit costs via efficiency.
- Enhances governance, operational resilience, and market trust.
Implementation Overview
- **Phased approachgovernance, scoping, design, testing, reporting.
- Applies to listed Japanese companies, multinationals with subsidiaries.
- Requires documentation, ITGC focus, annual assessments, no formal certification but FSA oversight.
Key Differences
| Aspect | CMMC | J-SOX |
|---|---|---|
| Scope | Cybersecurity for FCI/CUI in DoD contracts | Internal controls over financial reporting |
| Industry | Defense Industrial Base contractors | Japanese listed companies and subsidiaries |
| Nature | Mandatory certification for DoD contracts | Mandatory FIEA reporting for listed firms |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | Management evaluation + auditor attestation annually |
| Penalties | Contract ineligibility, debarment | Fines, imprisonment, delisting |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and J-SOX
CMMC FAQ
J-SOX FAQ
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