Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification verifying cybersecurity for FCI and CUI

    VS

    UAE PDPL

    Mandatory
    2022

    UAE federal regulation for personal data protection.

    Quick Verdict

    CMMC certifies DoD contractors' cybersecurity for FCI/CUI via tiered assessments, ensuring supply chain protection. UAE PDPL mandates privacy controls for personal data processors in UAE, safeguarding rights. Organizations adopt CMMC for contracts, PDPL for legal compliance.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

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

    Key Features

    • Tiered three-level model for FCI, CUI, APT protection
    • C3PAO third-party assessments verifying Level 2 compliance
    • Direct mapping to NIST SP 800-171 110 controls
    • Mandatory flow-down to DIB supply chain subcontractors
    • POA&Ms limited to 180-day closure timelines
    Data Privacy

    UAE PDPL

    Federal Decree-Law No. 45/2021 Personal Data Protection

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

    Key Features

    • Risk-based DPO and DPIA for high-risk processing
    • Extraterritorial scope for UAE residents' data
    • Mandatory Records of Processing Activities (RoPA)
    • GDPR-like data subject rights and transparency
    • Cross-border transfers via adequacy or safeguards

    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. DoD certification program ensuring cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) across the Defense Industrial Base (DIB). It uses a tiered, cumulative model with three levels, drawing from FAR 52.204-21 basic safeguards, NIST SP 800-171 Rev 2 (110 requirements), and NIST SP 800-172 enhancements.

    Key Components

    • **Three levelsLevel 1 (17 FAR practices), Level 2 (110 NIST controls across 14 domains like Access Control and Incident Response), Level 3 (+24 APT-focused controls).
    • Assessments via self-assessment (Levels 1/2), C3PAO (Level 2), or DIBCAC (Level 3).
    • System Security Plan (SSP), evidence artifacts, and limited POA&Ms (180-day closures).
    • Reporting to SPRS or eMASS with annual affirmations.

    Why Organizations Use It

    • Mandatory for DoD contract eligibility, preventing disqualification and debarment.
    • Mitigates supply chain risks, reduces breach costs, enhances resilience.
    • Provides competitive advantage, market access, and primes' subcontractor trust.

    Implementation Overview

    • **PhasedGovernance, scoping/gap analysis, remediation, pre-assessment, formal audit, sustainment.
    • Targets DIB primes/subcontractors handling FCI/CUI; enclaves for segmentation.
    • Requires cross-functional teams, tools like SIEM/MFA, triennial recertification.

    UAE PDPL Details

    What It Is

    UAE PDPL (Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data) is a comprehensive federal regulation establishing the UAE's first economy-wide framework for personal data processing. Effective from 2 January 2022, it applies onshore with risk-based approach, mandating controls proportionate to risks from new technologies, large volumes, or sensitive data.

    Key Components

    • Core principles: fairness, purpose limitation, minimization, accuracy, security, storage limitation.
    • Obligations: DPOs and DPIAs for high-risk processing; RoPAs for controllers/processors.
    • Data subject rights: access, portability, correction, erasure, objection.
    • No fixed control count; compliance via records, security, breach notification; enforced by UAE Data Office.

    Why Organizations Use It

    • Mandatory for onshore entities and foreign processors of UAE data subjects.
    • Mitigates fines, breach risks; builds trust in digital economy.
    • Aligns with GDPR for multinationals; enhances cybersecurity maturity.

    Implementation Overview

    Phased: discovery, gap analysis, remediation, operationalization. Applies to private sector onshore; excludes free zones, government, sectoral data. No certification; audit-ready records for regulator.

    Key Differences

    Scope

    CMMC
    Cybersecurity for FCI/CUI protection
    UAE PDPL
    Personal data processing and privacy

    Industry

    CMMC
    DoD contractors and subcontractors
    UAE PDPL
    All private sector in UAE onshore

    Nature

    CMMC
    Tiered certification model, mandatory for contracts
    UAE PDPL
    Federal law, mandatory compliance

    Testing

    CMMC
    Self-assess/C3PAO/DIBCAC every 3 years
    UAE PDPL
    DPIAs for high-risk, no formal certification

    Penalties

    CMMC
    Contract ineligibility, no direct fines
    UAE PDPL
    Administrative fines up to millions AED

    Frequently Asked Questions

    Common questions about CMMC and UAE PDPL

    CMMC FAQ

    UAE PDPL FAQ

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