CMMC
DoD framework certifying cybersecurity maturity for DIB contractors
U.S. SEC Cybersecurity Rules
U.S. SEC regulation mandating cybersecurity incident disclosures.
Quick Verdict
CMMC certifies DoD contractors' NIST controls for FCI/CUI via assessments, ensuring supply chain security. U.S. SEC rules mandate public companies disclose material incidents in 4 days and annual governance, enhancing investor transparency.
CMMC
Cybersecurity Maturity Model Certification 2.0
Key Features
- Three tiered levels aligned to FCI/CUI protection
- 110 NIST SP 800-171 controls with verification
- C3PAO third-party assessments for Level 2
- Limited POA&Ms with 180-day closure requirement
- SPRS reporting for DoD contract eligibility
U.S. SEC Cybersecurity Rules
Cybersecurity Risk Management, Strategy, Governance, Incident Disclosure
Key Features
- Four-business-day material incident disclosure on Form 8-K
- Annual risk management and governance in Item 106
- Inline XBRL tagging for structured data comparability
- Board oversight and management expertise disclosures
- Third-party risk processes explicitly required
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 framework verifying cybersecurity practices in the Defense Industrial Base (DIB). It protects Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) through tiered levels using a verification-based approach.
Key Components
- Three cumulative levels: Level 1 (17 FAR practices), Level 2 (110 NIST SP 800-171 controls), Level 3 (+24 NIST SP 800-172 enhancements).
- 14 domains like Access Control, Incident Response, Risk Assessment.
- Assessments via self, C3PAO, or DIBCAC; SPRS reporting; limited POA&Ms (180-day closure).
Why Organizations Use It
- Mandatory for DoD contracts handling FCI/CUI; ensures eligibility.
- Reduces supply chain risks, enhances resilience.
- Builds trust with primes, differentiates in bids.
- Lowers breach costs, aligns with NIST.
Implementation Overview
- Phased: scoping, gap analysis, remediation, assessment, sustainment.
- Targets DIB primes/subcontractors; all sizes.
- Requires C3PAO/DIBCAC certification every 3 years, annual affirmations.
U.S. SEC Cybersecurity Rules Details
What It Is
U.S. SEC Cybersecurity Rules (Release No. 33-11216), adopted July 2023, is a federal regulation amending Regulation S-K and Forms 8-K, 10-K, 20-F, 6-K. It standardizes disclosures for public companies under Exchange Act reporting, focusing on timely incident reporting and ongoing risk management to protect investors.
Key Components
- **Form 8-K Item 1.05Four-business-day disclosure of material cybersecurity incidents.
- **Regulation S-K Item 106Annual governance, strategy, risk processes in Form 10-K.
- Inline XBRL tagging for structured data.
- Materiality under securities law principles; no bright-line tests.
Why Organizations Use It
Enhances investor transparency, reduces information asymmetry; mandatory for registrants to avoid enforcement like Yahoo, Ashford cases. Improves capital efficiency, board oversight; addresses third-party risks amid rising threats.
Implementation Overview
Cross-functional playbooks, materiality frameworks, IRP updates; phased compliance (Dec 2023+). Applies to all public firms; no certification but SEC exams/enforcement.
Key Differences
| Aspect | CMMC | U.S. SEC Cybersecurity Rules |
|---|---|---|
| Scope | NIST-based controls for FCI/CUI protection | Public disclosure of incidents and governance |
| Industry | DoD contractors and subcontractors | All SEC registrants and public companies |
| Nature | Mandatory certification with assessments | Mandatory financial disclosures and reporting |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | Materiality determination and XBRL tagging |
| Penalties | Contract ineligibility and debarment | SEC enforcement and civil penalties |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and U.S. SEC Cybersecurity Rules
CMMC FAQ
U.S. SEC Cybersecurity Rules FAQ
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