Standards Comparison

    CMMC

    Mandatory
    2021

    DoD framework certifying cybersecurity for FCI and CUI

    VS

    NIST 800-171

    Mandatory
    2020

    U.S. standard for protecting CUI in nonfederal systems

    Quick Verdict

    CMMC certifies DoD contractors' cybersecurity maturity via tiered assessments for FCI/CUI, while NIST 800-171 provides the 110-control baseline it implements. Organizations pursue CMMC for contract eligibility; NIST 800-171 ensures foundational CUI protection across federal supply chains.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

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

    Key Features

    • Three tiered levels escalating from self-assessment to DIBCAC
    • Direct mapping to NIST SP 800-171/172 without additions
    • Independent C3PAO third-party verifications for Level 2
    • Mandatory flow-down across DIB supply chains
    • Enclave scoping for targeted FCI/CUI protection
    Controlled Unclassified Information

    NIST 800-171

    NIST SP 800-171 Protecting CUI in Nonfederal Systems

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

    Key Features

    • Protects CUI confidentiality in nonfederal contractor systems
    • 97 requirements across 17 control families in Rev 3
    • Requires SSP and POA&M for implementation documentation
    • Supports CUI enclave scoping to limit compliance scope
    • DFARS-mandated for DoD contractors with incident reporting

    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 program verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) across the Defense Industrial Base (DIB). It employs a tiered, cumulative model with three levels, drawing from FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172 for risk-aligned assurance.

    Key Components

    • **LevelsLevel 1 (17 basic FAR practices), Level 2 (110 NIST 800-171 controls), Level 3 (+24 NIST 800-172 enhancements).
    • 14 domains (e.g., Access Control, Incident Response) with practices assessed via interview, examine, test.
    • Built on NIST frameworks; certification valid 3 years with annual affirmations in SPRS/eMASS; limited POA&Ms (180-day closure).

    Why Organizations Use It

    • Mandatory for DoD contracts, ensuring eligibility and flow-down compliance.
    • Mitigates IP theft, supply chain risks; boosts resilience, reduces incidents.
    • Provides competitive edge, primes prefer certified subs; builds stakeholder trust.

    Implementation Overview

    • **PhasedGovernance, scoping/gaps, remediation, assessment (self/C3PAO/DIBCAC), sustainment.
    • Applies to all DIB firms handling FCI/CUI; enclave scoping aids SMEs.
    • Key: SSP development, evidence collection; triennial audits for Levels 2/3.

    NIST 800-171 Details

    What It Is

    NIST SP 800-171, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, is a U.S. government framework providing security requirements for safeguarding CUI confidentiality. It targets nonfederal entities like contractors, using a control-based approach tailored from NIST SP 800-53 Moderate baseline, focusing on systems processing, storing, or transmitting CUI.

    Key Components

    • 17 families in Rev 3 (97 requirements), expanded from 14 in Rev 2, including new areas like Planning (PL), Supply Chain Risk Management (SR).
    • Core elements: SSP, POA&M, assessment procedures via SP 800-171A.
    • Built on FIPS 200 and SP 800-53; supports tailoring and ODPs.
    • Compliance via self-assessment or third-party (e.g., CMMC Level 2).

    Why Organizations Use It

    • Mandatory for federal contractors via DFARS 252.204-7012.
    • Reduces breach risk, ensures contract eligibility, builds supply chain trust.
    • Strategic benefits: market access, resilience, FedRAMP equivalence.

    Implementation Overview

    Phased: scoping CUI enclave, gap analysis, control deployment (MFA, SIEM), documentation. Applies to contractors handling CUI; audits via examine/interview/test. (178 words)

    Key Differences

    Scope

    CMMC
    Tiered certification levels for FCI/CUI with 171 practices across 14 domains
    NIST 800-171
    110 requirements across 14 families for CUI confidentiality protection

    Industry

    CMMC
    DoD Defense Industrial Base contractors/subcontractors
    NIST 800-171
    All nonfederal organizations handling federal CUI

    Nature

    CMMC
    Mandatory DoD certification program with assessments
    NIST 800-171
    NIST baseline standard enforced via contracts

    Testing

    CMMC
    Self-assess Level 1/2 or C3PAO/DIBCAC every 3 years
    NIST 800-171
    Examine/interview/test per SP 800-171A procedures

    Penalties

    CMMC
    Contract ineligibility without certification
    NIST 800-171
    Contractual remedies, audits, potential debarment

    Frequently Asked Questions

    Common questions about CMMC and NIST 800-171

    CMMC FAQ

    NIST 800-171 FAQ

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