The defense industrial base (DIB) has been the target of mounting cyber-attacks, which continually increase in scope and complexity. In the interest of strengthening these critical systems, the United States Department of Defense (DoD) developed a robust cybersecurity certification model known as the CMMC. The CMMC program was unveiled to assess compliance with existing DoD cybersecurity requirements.  

To attain CMMC compliance, OSCs must work closely with authorized C3PAOs. However, not every entity qualifies as a C3PAO. Aspiring candidates must undergo a rigorous certification process, which explains why accredited C3PAOs are remarkably fewer than OSCs.  

As of December 2023, only forty-eight organizations had been awarded the prestigious title of CMMC C3PAO, with over 450 applicants in the waiting queue. While 48 approvals may sound like a welcome relief for existing OSCs, they still underscored a dire shortage of authorized CMMC assessors.  

In this blog, we uncover the process involved in earning CMMC C3PAO certification. But first, let’s start by reviewing common CMMC abbreviations and acronyms.   

Demystifying Relevant Abbreviations and Acronyms 

• C3PAO 

C3PAO, the CMMC acronym most relevant to this blog, stands for third-party assessor organization.  

It refers to agencies officially authorized to assist OSCs in undertaking cybersecurity audits in line with the Department of Defense’s CMMC protocols.  

• CMMC 

The Cybersecurity Maturity Model Certification (CMMC) is a framework developed by the DoD to gauge and certify the extent to which DIBs handle CUIs.  

The DoD released the CMMC Final Rule in October 2024, which will take effect in December of the same year, although full implementation is expected to start in mid-2025.  

• CUI 

Controlled unclassified information (CUI) refers to information that the federal government doesn’t consider classified but must be handled, stored, and released in strict adherence to certain laws and procedures.  

President Obama created the CUI program through Executive Order 13556, intending to streamline the sharing and safeguarding of sensitive information.  

• FCI 

 The terms federal contract information (FCI) and controlled unclassified information are commonly used interchangeably. However, they’re fundamentally different.  

FCI is unpublicized data that federal contractors acquire on behalf of a U.S. federal agency. Although both CUI and FCI are created or obtained by or on behalf of a federal department, CUI typically requires higher protection levels than FCI.  

• DIB 

The defense industrial base is a vast network of global organizations, corporations, and facilities that avail diverse products and services to the U.S. Department of Defense.  

DIBs typically develop, deliver, and maintain military weapons and systems. However, some also offer financial, logistical, and other auxiliary products and services to the federal agency.  

Each defense contractor must agree to secure sensitive information in their contract documents as required by DFARS clause 252.204-7012. 

• NIST 

The National Institute of Standards and Technology (NIST) is a suite of tools and protocols founded in 1901, which defines the security standards for various industries and government institutions. CMMC C3PAO assessors must be up to date on the latest CMMC and NIST revisions, as both security protocols are intertwined.  

CMMC largely draws from NIST 800-171, which defines how DIBs should safeguard CUI’s privacy and confidentiality. NIST 800-171 provides the standards for CUI compliance, while CMMC details the process for achieving NIST (and other cybersecurity) certifications. 

• CMMC AB 

CMMC Accreditation Body (CMMC AB) is the umbrella organization under which Cyber AB falls. It plays a significant role in ensuring C3PAOs meet the minimum security standards for safeguarding CUI and FCI. 

• Cyber AB 

Cyber Accreditation Body (Cyber AB) refers to the official accreditation body used within the CMMC ecosystem. CMMC AB maintains the standards that C3PAOs must satisfy to be certified for CMMC audits. 

• OSC 

Organizations seeking compliance (OSC) are companies that enlist C3PAO services to assess their compliance with CMMC regulations.  

Why Become A C3PAO? 

According to the Cybersecurity and Infrastructure Security Agency (CISA), there are over 100,000 DIB companies. This excludes subcontractors and other small-time CUI handlers.  

Meanwhile, only a handful of C3PAOs have been certified so far. Since all DIBs must undertake routine CMMC compliance assessments, becoming a CMMC C3PAO can provide a lucrative employment opportunity.  

Working as a C3PAO also confers you a unique privilege to help the federal government bolster CUI security across all systems that handle such information.  

What Are the Prerequisites for Obtaining A C3PAO Accreditation? 

Completing a CMMC Level 3 assessment is the minimum requirement to become a C3PAO. Prospective candidates must also possess ISO 9001 and ISO 27000, as well as CMMI Maturity Level 2 and 3 certifications.  

Moreover, a C3PAO applicant must have minimum insurance coverage, which includes general liability insurance. The said insurance must clearly name ‘CMMC Accreditation Body’ as the insured and must cover data-related risks, such as “cybersecurity breaches” and “errors and omissions.”  

Below are other preconditions for aspiring C3PAOs; 

• Must be 100% a US citizen-owned company 

• Must have their third-party cloud services independently audited to ensure they meet the minimum FedRAMP requirements 

• Must be subject to organizational background screening through Dun & Bradstreet, with the checks culminating in a Data Universal Numbering System (DUNS) number. 

• Each constituent member of a C3PAO assessment team must possess DoD Accepted Clearance status, such as the National Armaments Consortium (NAC) and DHS Suitability. 

• Must demonstrate proof of trained staff and satisfactory cybersecurity health across all IT and data systems 

Exploring the Phases of Obtaining CMMC C3PAO Certification 

Phase-1: Candidacy 

The first step in obtaining C3PAO certification is to declare your interest in accreditation to the CMMC AB. Expectedly, you’ll have to fulfill certain critical conditions for the CMMC AB to consider your application.  

First, your company will need to follow the C3PAO application process outlined on the CMMC-AB website. The procedure entails signing a C3PAO License Agreement, after which you provide evidence of insurance coverage.  

Next is fee payment. There’s a $1,000 application fee and a $2,000 activation fee, both non-refundable.  

Phase-2: Approval 

Tendering a C3PAO application is relatively easy. It’s the approval phase where the rubber meets the road.  

In this stage, you must complete an organizational background check through Dun & Bradstreet. The screening allows Dun & Bradstreet to supply CMMC AB with a DUNs number – a nine-digit number assigned to each business entity as a unique identifier.  

Besides, you must maintain at least one staffer who has been duly trained to prepare OSCs for CMMC assessments. The employee could be a member of your in-house IT team or an outsourced IT cyber professional. Whichever the case, the individual must possess at least one of the below CMMC-related certifications; 

• Registered Practitioner 

• Provisional Assessor 

• Certified Assessor 

• Certified Professional 

If you do not already have a trained staff, there’s a 30-day grace period to make that arrangement.  

It’s also at this phase that you’ll need to confirm your organization is 100% owned by a U.S. citizen. That shouldn’t be a problem if you’re already a legal citizen. But if you’re applying for C3PAO certification under another company’s auspices, then it’s something to pay keen attention to.  

The CMMC AB requires organizations that aren’t owed 100% by U.S. citizens to successfully pass a Foreign Ownership, Control or Influence (FOCI) investigation. Completing a FOCI test prevents undue influence of the C3PAO application process, which could jeopardize its credibility and integrity.  

The final step of phase 2 is arguably the most important. It entails undertaking a CMMC Level 3 assessment, which is administered by the Defense Industrial Base Cybersecurity Assessment Center (DIBAC).  

DIBAC’s requirements for awarding CMMC Level 3 certification vary across organizations. While you may not always be dismissed at the first failure, passing the test might necessitate revamping your cybersecurity protocols. 

Phase 3: Authorization  

Congratulations on passing all phase-2 tests! You’re now ready for authorization.  

However, to obtain full authorization, you must prove that you have the requisite human and financial resources to sustain C3PAO Authorization.  

Interestingly, the CMMC AB may require proof of maintaining several trained IT personnel even if you have made it this far by providing information on only one individual. So, it’s prudent to engage a sizable cyber workforce before embarking on the C3PAO application process.  

Phase 2 is also where evidence of ISO 17020 certification is paramount. This certification validates that you have the requisite instruments and governance architectures to perform impartial CMMC assessments.  

Remember that the idea isn’t to make quick bucks from each CMMC audit. Rather, it’s to help OSCs understand if they strictly adhere to the DoD’s cybersecurity protocols and avoid harsh non-compliance penalties.  

There’s a 27-month window from the date you first registered for C3PAO certification to acquire the relevant ISO certifications. 

Phase-4: Accreditation 

The final step in the C3PAO application is to obtain full accreditation. Receiving certification doesn’t merely validate that you satisfy all previous requirements. It also demonstrates your ability to undertake comprehensive CMMC audits.  

After successful accreditation, your company will now appear in the CMMC marketplace for OSCs.  

Note that C3PAO certification is renewable annually at a fee of $2,000. Besides, you may incur additional costs in training more personnel and upgrading your cybersecurity systems occasionally. That’s not to mention the ongoing training costs and maintaining your in-house assessors.  

So, it pays to define your budget before applying to become a C3PAO.  

Most importantly, you must always be current on CMMC compliance requirements to conduct accurate, verifiable, quality cybersecurity audits. Don’t forget to watch out for any regulatory trends around CMMC, NIST 800-171, and other CUI-related protocols.  

Summary 

As many organizations jostle for CMMC compliance, there’s a need to certify more C3PAOs who would assist OSCs in undertaking the significant task of evaluating their CMMC compliance. If you’re in the cybersecurity industry, now is the most opportune time to step in the gap and capitalize on the glaring shortage of C3PAOs.  

Becoming a CMMC C3PAO is a lucrative career opportunity. Besides, it broadens your knowledge of emerging cybersecurity threats and how you can navigate these risks to secure your sensitive information.  

An excellent starting point for any aspiring C3PAO is understanding what these professionals do, their role in securing DIBs, and (more importantly) how to become one.