What is the primary objective of **CMMC**?

**The primary objective of CMMC is to verify that Defense Industrial Base (DIB) organizations have implemented cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).** CMMC operationalizes requirements from FAR 52.204-21 (15 practices at **Level 1**), NIST SP 800-171 Rev. 2 (110 practices at **Level 2**), and NIST SP 800-172 (24 enhanced practices at **Level 3**), using a tiered model with defined assessment pathways to ensure supply chain protection against cyber threats.

Who is legally or professionally required to comply with **CMMC**?

**All DoD primes and subcontractors processing, storing, or transmitting FCI or CUI must comply with CMMC.** Contract solicitations specify the required **CMMC level**, with flow-down obligations via DFARS 252.204-7021 excluding only COTS items; this affects over 300,000 DIB entities across manufacturing, IT, and logistics.

Does **CMMC** require an external audit or third-party certification?

**CMMC requires external audits or third-party certification depending on the level and contract.** **Level 1** mandates annual self-assessments with SPRS affirmation; **Level 2** allows triennial self-assessments (OSA) or C3PAO certification (eMASS reporting), with annual affirmations; **Level 3** requires prerequisite **Level 2** C3PAO certification plus triennial DIBCAC assessment.

How often should an assessment for **CMMC** be performed?

**CMMC assessments occur annually for affirmations and every three years for full certification.** **Level 1** requires annual self-assessments and SPRS affirmations; **Level 2** needs triennial self-assessments or C3PAO with annual affirmations; **Level 3** mandates triennial DIBCAC assessments post-**Level 2** C3PAO, plus annual affirmations; certification validity is three years.

What are the consequences of non-compliance with **CMMC**?

**Non-compliance with CMMC results in contract ineligibility, potential suspension, debarment, and remediation costs.** Bidders without required certification risk disqualification from DoD solicitations; primes must withhold FCI/CUI from non-compliant subcontractors, exposing organizations to audits, contractual remedies, and supply chain compromises under DFARS clauses.

Can **CMMC** be mapped to other international frameworks?

**No, these FAQs address CMMC independently without mappings to other frameworks.** CMMC stands alone as a DoD-specific program verifying NIST-aligned controls via its tiered model and assessment processes.

What is the first step to begin implementing **CMMC**?

**The first step to implement CMMC is to obtain executive sponsorship and conduct scoping per DoD and CMMC Scoping Guides.** Form a cross-functional team, map FCI/CUI boundaries to define assessment scope (enterprise or enclaves), and develop an initial System Security Plan (SSP) skeleton for gap analysis against the target level's controls.

What is the primary objective of **MLPS 2.0 (Multi-Level Protection Scheme)**?

**MLPS 2.0 (Multi-Level Protection Scheme) establishes a legally mandated, graded cybersecurity framework to protect information systems based on their potential impact on national security, social order, and public interests.** It classifies systems into five levels (1-5), requiring commensurate technical, management, physical, and personnel controls per GB/T 22239-2020 standards. Objectives include preventing breaches, ensuring consistent nationwide security baselines, and enabling law enforcement oversight via Ministry of Public Security (MPS).

Who is legally or professionally required to comply with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**All network operators in mainland China, including domestic firms, foreign-invested enterprises, and multinationals with local systems, must comply with MLPS 2.0 (Multi-Level Protection Scheme).** This covers virtually every entity operating IT networks, cloud services, IoT, big data, or industrial controls under Article 21 of the 2017 Cybersecurity Law. Critical sectors like finance, energy, and telecom often classify at Level 3+.

Does **MLPS 2.0 (Multi-Level Protection Scheme)** require an external audit or third-party certification?

**Yes, MLPS 2.0 (Multi-Level Protection Scheme) mandates external security reviews by licensed Chinese firms for Level 2+ systems, with PSB approval.** Reviews score compliance (minimum 75/100) across technical, management, and physical domains per GB/T 28448-2019. Level 1 requires self-assessment only; higher levels demand documentation submission and potential on-site inspections.

How often should an assessment for **MLPS 2.0 (Multi-Level Protection Scheme)** be performed?

**MLPS 2.0 (Multi-Level Protection Scheme) requires periodic re-evaluations: biennially for Level 2, annually for Level 3, semi-annually for Level 4, and as mandated for Level 5.** Self-inspections occur continuously, with third-party audits and PSB reviews triggered by changes in system architecture, data sensitivity, or operating environment.

What are the consequences of non-compliance with **MLPS 2.0 (Multi-Level Protection Scheme)**?

**Non-compliance with MLPS 2.0 (Multi-Level Protection Scheme) results in fines up to 100,000 yuan, operational suspensions, system shutdowns, and intensified PSB inspections.** Enforcement links certification to business license renewals; severe cases involve blacklisting or criminal liability, as seen in financial sector fines exceeding RMB 200 million.

Can **MLPS 2.0 (Multi-Level Protection Scheme)** be mapped to other international frameworks?

**Yes, MLPS 2.0 (Multi-Level Protection Scheme) control domains—governance, physical, network, data, and operations—map to frameworks like ISO 27001 Annex A and NIST CSF.** Organizations leverage existing ISMS Statements of Applicability for gap analysis, though MLPS adds prescriptive grading, data localization, and PSB oversight unique to China.

What is the first step to begin implementing **MLPS 2.0 (Multi-Level Protection Scheme)**?

**The first step for implementing MLPS 2.0 (Multi-Level Protection Scheme) is conducting a provisional self-assessment to classify systems into Levels 1-5 based on impact to national security, social order, and public interests.** Inventory assets, document rationale per GB/T 22240-2020, and engage cross-functional teams for filing with local PSBs within 30 days for Level 2+ systems.

CMMC vs MLPS 2.0 (Multi-Level Protection Scheme)

Standards Comparison

CMMC

Mandatory

2021

DoD certification for DIB cybersecurity maturity levels

MLPS 2.0 (Multi-Level Protection Scheme)

Mandatory

2019

China's mandatory graded protection scheme for network security

Quick Verdict

CMMC certifies DoD contractors for FCI/CUI via NIST controls and phased assessments, ensuring supply chain security. MLPS 2.0 mandates graded protection for all Chinese networks with PSB enforcement. Firms adopt CMMC for US defense contracts; MLPS for China market access.

Cybersecurity Maturity

CMMC

Cybersecurity Maturity Model Certification (CMMC) 2.0

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

Three cumulative levels aligned to FAR/NIST standards
C3PAO third-party assessments for Level 2 certification
DIBCAC assessments for Level 3 APT defenses
180-day POA&M limits for conditional compliance
DFARS-mandated subcontractor flow-down requirements

Cybersecurity

MLPS 2.0 (Multi-Level Protection Scheme)

Multi-Level Protection Scheme 2.0 (MLPS 2.0)

Cost

€€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Five-level impact-based system classification
Mandatory PSB registration and approval for Level 2+
Third-party audits with 75/100 minimum score
Extended controls for cloud, IoT, ICS, big data
Law enforcement oversight and periodic re-evaluations

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 practices for the Defense Industrial Base (DIB). It protects Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) via a tiered, risk-based model with three cumulative levels.

Key Components

**Three levelsLevel 1 (17 FAR 52.204-21 practices), Level 2 (110 NIST SP 800-171 Rev 2 controls across 14 domains), Level 3 (+24 NIST SP 800-172 enhancements).
Built on NIST standards; uses System Security Plans (SSPs) and Plans of Action & Milestones (POA&Ms) with 180-day closures.
Assessments via self, C3PAO, or DIBCAC, reported to SPRS/eMASS.

Why Organizations Use It

Mandated in DoD contracts for eligibility; reduces breach risks, enhances supply chain trust, and provides competitive procurement advantage. Builds operational resilience and aligns with NIST frameworks.

Implementation Overview

Phased approach: scoping/gap analysis, remediation, assessment preparation. Applies to DIB contractors/subcontractors; complex for SMEs but scalable via enclaves. Requires annual affirmations, 3-year recertifications.

MLPS 2.0 (Multi-Level Protection Scheme) Details

What It Is

MLPS 2.0 (Multi-Level Protection Scheme 2.0) is China's legally mandated cybersecurity framework under the 2016 Cybersecurity Law. It requires network operators to classify systems into five protection levels based on potential harm to national security, social order, and public interests, implementing graded technical and governance controls.

Key Components

Core domains: physical security, network protection, data security, access control, monitoring, governance.
Standards like GB/T 22239-2020, GB/T 25070-2019 define baselines, extended for cloud, IoT, ICS.
Common controls for all levels, plus level-specific requirements.
Compliance via self-classification, third-party audits (75/100 score min for Level 2+), PSB approval.

Why Organizations Use It

Mandatory for all China network operators; non-compliance risks fines, suspensions.
Enhances resilience, supports market access, aligns with data laws.
Builds regulator trust, reduces breach risks.

Implementation Overview

Phased: scoping, classification, gap analysis, remediation, audits, ongoing re-evaluations.
Applies to all sizes in China; Level 3+ needs annual audits.
Involves governance setup, documentation, PSB filings.

Key Differences

Aspect	CMMC	MLPS 2.0 (Multi-Level Protection Scheme)
Scope	FCI/CUI protection in 14 NIST domains	All networks across physical/data/ops domains
Industry	DoD contractors/subcontractors (US DIB)	All network operators in mainland China
Nature	Certification program with self/C3PAO assessments	Mandatory legal regime enforced by PSBs
Testing	Self-assess Level 1/2 or C3PAO/DIBCAC every 3 years	Third-party audits Level 2+ with PSB approval
Penalties	Contract ineligibility, no direct fines	Fines, operational suspension, license revocation