This shift from NIST to CMMC will affect over 300,000 companies within the DoD supply chain. This article compares the CMMC and NIST frameworks, elucidating the forthcoming changes that defense contractors and related entities must acknowledge. The transition to CMMC will be gradual, but by 2026, it will be an integral component of all defense contracts, making it a matter that cannot be overlooked.
CMMC vs. NIST Compliance: Key Differences
The most prominent distinction between NIST and CMMC compliance lies in their approach. The CMMC policy employs a maturity model consisting of different cybersecurity sophistication levels contractors can achieve through third-party assessments. These maturity levels are sequential tests, where progression to the next level is contingent upon passing the previous one.
CMMC comprises five maturity levels:
- Level 1: Basic cybersecurity requirements focused on safeguarding federal contact information (FCI) and controlled unclassified information (CUI), emphasizing basic computer hygiene with undocumented processes.
- Level 2: Contractors meet, measure, and document cybersecurity requirements to demonstrate CMMC implementation, marking the beginning of process documentation.
- Level 3: Active management and assessment of cybersecurity practices to prove compliance. Contractors must present a CMMC implementation plan with staff training programs and milestones.
- Level 4: Subcontractors review their practices to ensure they meet cybersecurity requirements and take corrective measures if necessary.
- Level 5: The highest level of CMMC compliance, requiring adherence to CMMC Level 5 standards across all departments and processes.
Why CMMC Is More Robust Than NIST
CMMC surpasses NIST in several aspects:
- Mandatory Compliance: While NIST compliance is voluntary, CMMC compliance will be obligatory for all Defense Department contractors by 2026. This shift enhances cybersecurity by necessitating that every contractor attains CMMC accreditation matching the sensitivity of the data they handle. Contractors with subpar cybersecurity standards must upgrade to an appropriate CMMC level to handle sensitive data.
- Third-Party Assessment: CMMC accreditation involves third-party assessment by the CMMC Accreditation Body (CMMC-AB), consisting of independent groups known as third-party assessment organizations (C3PAOs). These organizations review contractors before assigning a CMMC maturity level. Noncompliant contractors risk losing their contracts. Only C3PAOs accredited by the CMMC-AB can conduct CMMC assessments, ensuring strict adherence to the framework.
The Department of Defense plans a phased rollout of CMMC requirements over the next five years, culminating in full compliance by 2026.
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