Imagine your company is in talks to land a major contract with the U.S. Department of Defense. Exciting, right? But before you can start celebrating, there's a crucial hurdle you need to clear: proving that your cybersecurity practices are up to par. This is where the Cybersecurity Maturity Model Certification (CMMC) comes into play. And at the heart of this process is something called a C3PAO — Certified Third-Party Assessor Organization.

Think of a C3PAO as a trusted expert who steps in to assess your company’s cybersecurity readiness. Their job is to evaluate whether you’re meeting the security standards required by the CMMC framework, especially if you're handling sensitive information that requires Level 2 certification. This isn’t just a box-ticking exercise; it’s about ensuring that your business can protect vital and sensitive data that could be critical to national security, making you eligible to work on those highly coveted DoD contracts.

In this article, we’ll break down exactly what a C3PAO is, the role they play in the CMMC certification process, and why they’re so important for companies looking to secure government contracts. 

What does C3PAO mean? 

C3PAO is an acronym that stands for Certified Third-Party Assessor Organization. 

These are the entities that have been authorized by the Cybersecurity Maturity Model Certification Accreditation Body (The Cyber AB) to conduct formal CMMC assessments. While the C3PAO does not directly issue the certification, they submit the assessment results to the CMMC-AB. The CMMC-AB reviews the assessment report provided by the C3PAO, and based on this review, officially grants certification to the organization.

Having a neutral, qualified third-party assess your organization’s level of CMMC 2.0 compliance adds the level of validation needed for Critical Level 2 certification. Having an outside expert conduct the certification ensures that the organization meets the necessary security requirements to protect CUI, FCI, and other sensitive data when working on DoD contracts.

C3PAO vs government-led assessments

Under CMMC 2.0, the key difference between a C3PAO-led assessment and a government-led assessment lies in who conducts the evaluation and the level of certification required.

A C3PAO-led assessment is typically required for organizations that handle critical CUI seeking Level 2 certification. The assessment ensures the organization meets the necessary security requirements to protect CUI in compliance with the CMMC Level 2 framework. After the assessment, the C3PAO submits the results to the CMMC Accreditation Body, which then decides on the certification. Assessments must be conducted every three years to maintain an active CMMC Level 2 certification. 

A government-led assessment is conducted directly by the Department of Defense or another authorized government entity and is required for organizations seeking CMMC Level 3 certification. These are companies handling highly sensitive data requiring advanced, adaptive cybersecurity practices. This is the most rigorous type of CMMC assessment due to the data involved. 

Tips for navigating the CMMC C3PAO Marketplace and selecting an assessor

Accredited CMMC C3PAOs are listed on The Cyber AB Marketplace. Using the filters, select ‘C3PAO’ under ‘Ecosystem Role’ and ‘Assessment Services’ under ‘Scope of Services’. You can further refine your selection criteria based on the level of experience and geographical location you’re looking for. 

In addition to assessment services, you can find C3PAOs that offer continuous monitoring and surveillance, penetration testing, third-party risk management, virtual CISO, and more cybersecurity services to help you prepare and maintain CMMC certification. 

While you might be tempted to select the first available C3PAO, it’s important to carefully consider and choose one that aligns with your organization’s needs. Here are some factors to consider when choosing a C3PAO for your CMMC assessment. 

Compatibility 

The most important element in selecting a C3PAO is their understanding of your organization’s needs and compliance requirements. Look for an assessor that will offer a tailored approach to your organization’s specific needs, considering your current cybersecurity posture and any gaps that need addressing. 

If you have other frameworks that you need to comply with such as SOC 2, ISO 27001, or NIST 800-53 it might be in your interest to find a C3PAO that can also audit for the other frameworks in order to drive efficiency for your organization. Communication will be crucial here, so find someone who can not only be an auditor but also a partner to help clearly communicate and work through the assessment process, expectations, and any potential challenges.

Familiarity with your tech stack

If you're using a compliance automation tool to simplify the CMMC readiness process, it can be beneficial to partner with an assessor that's familiar with the tool. This enables them to streamline the assessment process, including the review of your documentation.

Schedule and cost

Ensure the C3PAO provides clear and transparent pricing, without any hidden fees or additional costs that might arise during the assessment process. It’s also crucial to confirm that the C3PAO can work within your required timeframe, especially if you have deadlines tied to specific contracts or regulatory requirements.

Post-assessment support

Depending on the level of in-house expertise you have, it can be advantageous to partner with a C3PAO that can provide support for maintaining compliance after certification, such as ongoing monitoring or document maintenance, which can be crucial for passing future assessments.

Carefully considering these factors will help you select a C3PAO that is well-equipped to guide your organization through the CMMC certification process efficiently and effectively.

FAQs

What is a C3PAO in CMMC?

A C3PAO, or Certified Third-Party Assessor Organization, is an entity authorized by the Cybersecurity Maturity Model Certification Accreditation Body (The Cyber AB) to conduct assessments for companies seeking CMMC certification. C3PAOs evaluate an organization's compliance with the cybersecurity practices required under the CMMC framework, particularly for companies aiming to achieve Level 2 certification. The assessment results are submitted to the CMMC-AB, which then decides whether to grant the certification.

What is CMMC Level 3 compliance?

CMMC Level 3 compliance represents the highest level of cybersecurity maturity within the CMMC 2.0 framework. It is designed for companies handling the most sensitive Controlled Unclassified Information (CUI) and involves implementing advanced/progressive cybersecurity practices.

How to become a CMMC 3PAO?

To become a CMMC C3PAO, an organization must go through the following steps:

  1. Submit an application to the CMMC Accreditation Body (The Cyber AB).
  2. Meet requirements. This includes possessing the necessary cybersecurity expertise and having certified assessors on staff, as well as completing an assessment to meet CMMC Level 3 requirements.
  3. If requirements are successfully met, the organization is certified by The Cyber AB as a C3PAO and listed on the CMMC Marketplace.
  4. The C3PAO must maintain certification by adhering to CMMC standards and may be subject to periodic reassessments or audits by the Cyber AB.
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