CMMC
DoD certification verifying cybersecurity maturity in DIB
SOX
U.S. federal law for financial reporting accountability
Quick Verdict
CMMC certifies cybersecurity for DoD contractors protecting FCI/CUI, while SOX mandates ICFR for public companies ensuring financial reporting integrity. DoD firms adopt CMMC for contract eligibility; public firms use SOX to avoid penalties and build investor trust.
CMMC
Cybersecurity Maturity Model Certification (CMMC 2.0)
Key Features
- Three cumulative certification levels aligned to NIST
- Third-party C3PAO and DIBCAC assessments
- SPRS/eMASS reporting with annual affirmations
- Enclave scoping for precise compliance boundaries
- POA&Ms limited to 180-day closures
SOX
Sarbanes-Oxley Act of 2002
Key Features
- CEO/CFO certification of financial reports (Section 302)
- ICFR management assessment and auditor attestation (Section 404)
- PCAOB oversight of public company auditors (Title I)
- Auditor independence and rotation requirements (Title II)
- Criminal penalties for false certifications (Section 906)
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) in the Defense Industrial Base (DIB). It uses a tiered, risk-based model with three cumulative levels drawn from FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
Key Components
- 14 domains (e.g., Access Control, Incident Response) with 17 Level 1, 110 Level 2, and 24 additional Level 3 practices.
- Assessment via self, C3PAO, or DIBCAC using interview/examine/test methods.
- System Security Plans (SSPs), POA&Ms (180-day limits), and reporting to SPRS/eMASS.
- Annual affirmations; triennial certifications.
Why Organizations Use It
Mandated for DoD contracts, ensuring eligibility and flow-down compliance. Reduces breach risks, enhances supply chain trust, lowers insurance costs, and provides competitive bidding advantage amid APT threats.
Implementation Overview
Phased approach: scoping/gap analysis, remediation, assessment prep, certification, sustainment. Targets DIB primes/subcontractors (SMEs to enterprises); requires cross-functional teams, tools like SIEM/MFA. Costs $100K+ for Level 2; 12+ months typical.
SOX Details
What It Is
Sarbanes-Oxley Act of 2002 (SOX) is a U.S. federal statute regulating corporate governance and financial disclosures for public companies. Its primary purpose is protecting investors by ensuring accurate, reliable financial reporting. SOX employs a risk-based, control-oriented approach focused on internal controls over financial reporting (ICFR).
Key Components
- **Three pillarsPCAOB oversight (Title I), auditor independence (Title II), executive accountability (Titles III–XI).
- Key sections: 302 (CEO/CFO certifications), 404 (ICFR assessments), 409 (real-time disclosures).
- Built on COSO framework; no fixed controls, emphasizes key controls and ITGCs.
- Compliance via annual management reports and auditor attestation (404(b)).
Why Organizations Use It
- Mandatory for U.S. public issuers; reduces restatements, builds investor trust.
- Enhances risk management, fraud deterrence, operational efficiency.
- Lowers cost of capital; aids M&A/IPO readiness.
Implementation Overview
- Phased: scoping, design, testing, monitoring using top-down risk assessment.
- Applies to public companies; scalable for size.
- Requires annual audits; ongoing continuous monitoring.
Key Differences
| Aspect | CMMC | SOX |
|---|---|---|
| Scope | Cybersecurity for FCI/CUI in DoD contracts | Financial reporting internal controls (ICFR) |
| Industry | Defense Industrial Base contractors | All U.S. public companies |
| Nature | Mandatory certification for DoD contracts | Mandatory federal law with PCAOB enforcement |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | Annual ICFR testing and auditor attestation |
| Penalties | Contract ineligibility and debarment | Fines, imprisonment, civil/criminal liability |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and SOX
CMMC FAQ
SOX FAQ
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