Any company that seeks to enter a contractual engagement with the United States Department of Defense (DoD) will now be obligated to comply with all applicable protocols in the DoD’s newly revised CMMC framework.  

In fact, CMMC compliance won’t merely be a mandatory condition for securing defense contracts. All businesses that handle DoD-designated sensitive information will be required to demonstrate their continued commitment to safeguarding the Defense Industrial Base (DIB) from unprecedented cyber-attacks.  

Sadly, a recent survey by Redspin uncovered a glaring readiness gap in implementing CMMC protocols. Over half of the respondents indicated they weren’t prepared enough for CMMC requirements, underscoring a need for intensified awareness of the significance of CMMC adoption.  

But while many DIB companies prefer to adopt a wait-and-see attitude, you can get ahead of the competition by kick-starting your CMMC certification today. A critical part of CMMC compliance entails conducting cybersecurity audits facilitated by independent CMMC-accredited auditors known as C3PAOs. Read below as we dissect the role of a C3PAO in accelerating CMMC compliance and certification. 

What Is CMMC? 

The Cybersecurity Maturity Model Certification, commonly abbreviated as CMMC, is a program designed by the Department of Defense to enforce the safe handling of DoD-designated sensitive information.  

CMMC assesses compliance with various security protocols published by the National Institute of Standards and Technology (NIST). It mostly safeguards the dissemination of Critical Unclassified Information (CUI) and Federal Contract Information (FCI).  

CUI and FCI encompass sensitive information created by or collected on behalf of the US federal government. However, while both are subjected to strict control measures, they differ in their intended consumers. FCI is strictly intended for consumption by federal agencies and their contractors. It differs from CUI, which may be released to the general public. The DoD announced the release of the revised CMMC framework in October 2024. Since then, forward-thinking defense contractors have made frantic efforts to achieve compliance. 

Who Is A C3PAO? 

C3PAOs stands for CMMC Third-Party Assessor Organizations, often known alternatively as Certified Third-Party Assessor Organizations. They refer to individuals or agencies mandated to conduct CMMC compliance audits.  

C3PAOs are authorized by the CMMC accreditation body – The Cyber AB or CMMC AB. They perform cyber audits on behalf of Organizations Seeking Assessment (OSAs) and in strict adherence to the CMMC’s framework.  

Unlike regular cybersecurity assessors who may doctor audit reports to suit their clients’ interests, C3PAOs guarantee independent and unbiased audits. That’s because they only answer to their accreditation body – the Cyber AB.  

To become a C3PAO, an organization must undergo a rigorous qualification process by the Cyber AB and the Defense Industrial Base Cybersecurity Assessment Center (DIBAC). Prospective assessors must demonstrate possession of the necessary equipment, technology, and expertise to conduct accurate CMMC evaluations. 

Are C3PAOs Synonymous With 3PAOs? 

Despite being nearly homonymous, C3PAOs and 3PAOs serve quite distinct functions.  

3PAOs (Third Party Assessment Organizations) are responsible for evaluating the security of Cloud Service Offerings (CSOs) on behalf of the Federal Risk and Authorization Management Program (FedRAMP). They conduct initial and periodic cyber assessments to ensure seamless access to secure cloud systems. 

The Role of C3PAOs in CMMC Certification

1. C3PAOs Help Uphold CMMC Compliance

The defense industrial base has recorded a wave of direct cyber-attacks over the past decade. Initially, most DoD-targeted cyber wars were waged against central military installations and logistic systems. However, recent attacks have notably targeted civilian infrastructures critical to military operations.  

Some cyber wars have strained the already frosty relationship between the United States and its arch-nemesis, like China and Russia, as evidenced in a 2023 report by the Center for Strategic and International Studies (CSIS). The CSIS report noted a significant increase in Chinese cyber-attacks against the U.S. DIB and other critical infrastructures, raising the simmering tensions between the two countries.  

Examples of Recent Cyber-attacks Targeting Defense Infrastructures 

The SolarWinds cyber-attack in 2020 is one of the most aggressive cyber breaches to have targeted defense infrastructures in recent memory. The attack, which was reportedly perpetrated by a group of cyber criminals backed by the Russian government, occurred when hackers deployed malware to gain access to the SolarWinds Orion platform during routine software updates.  

Note that SolarWinds provides IT monitoring and management solutions to thousands of government and private enterprises worldwide, including the Department of Defense. Therefore, hacking the company’s software led to a massive breach of CUI and FCI, potentially jeopardizing national security.  

Estimates suggest that well over 18,000 systems worldwide got infected, leading to billions of dollars in financial losses and a publicity nightmare for the affected companies. Hardly a year had gone by when yet another major attack occurred.  

On May 8, 2021, the Colonial Pipeline Company announced halting its pipeline operations after a major ransomware cyber-attack on its computerized equipment. The attack occurred when a group of hackers called themselves DarkSide breached an employee’s log-in credentials, which were likely obtained on the dark web.  

The Colonial Pipeline mainly conveys gasoline and jet fuel to the Southern United States. The oil pipeline system shut down for five days during the ransomware attack, causing acute oil shortages and panic buying in the affected regions. But more interesting is that data worth 100 gigabytes ended up in malicious hands within only a space of two hours. That potentially included sensitive defense information, considering that the DoD is one of Colonial Pipeline’s clients.  

The Colonial Pipeline cyber-attack was also one of the most recent high-profile breaches to have targeted defense suppliers rather than the DoD’s central command and logistics systems. That notwithstanding, the damage was devastating.  

Where Do C3PAOs Come In? 

In light of intensified cyber-attacks targeting the defense industrial base, the DoD introduced a new and revamped CMMC framework. By requiring all defense contractors to comply with relevant CMMC standards for handling CUI and FCI, the federal agency seeks to reduce cyber breaches targeting its supply chain.  

C3PAOs play the most significant role in enforcing CMMC compliance by helping OSAs identify and seal vulnerabilities in their cybersecurity ecosystems. A CMMC C3PAO enables defense contractors to understand better their IT assets that store CUI and FCI. They then recommend proper strategies for handling such information in line with the CMMC framework.  

However, C3PAOs don’t just help OSAs understand their CMMC compliance status. Each cybersecurity assessment culminates in a report shared with the DoD through the Cyber AB. These audit reports highlight the extent to which a contractor satisfies CMMC’s protocols, informing critical security decisions.  

For instance, the DoD may determine if an audited firm deserves to be awarded defense tenders. The agency may also prescribe appropriate penalties, especially for gross non-compliance. CMMC C3PAOs are mostly involved in ensuring CMMC Level 2 compliance.  

C3PAO assessments enable defense contractors to establish whether they handle information relevant to Level 2 CMMC certification. If such information exists, the audits will verify if the organization manages the sensitive information in line with the 110 cybersecurity protocols under CMMC Level 2.  

2. C3PAOs Help OSAs Maintain High Cyber Hygiene

While all aspiring defense contractors must undergo mandatory CMMC compliance audits, any company can enlist the services of a C3PAO. As mentioned, C3PAOs perform comprehensive and unbiased audits. Their assessments allow organizations to understand their cybersecurity posture and make improvements where necessary. 

When you engage a C3PAO, the professional will start by scoping your cybersecurity architecture for CMMC gaps and vulnerabilities. They’ll then compile a detailed report highlighting interventions for sealing any loopholes uncovered during the audit process.  

Even if C3PAO audit reports don’t pick out any vulnerabilities, they provide a better understanding of your current cybersecurity hygiene. This can be instrumental in helping you avert threats in your supply chain. CMMC C3PAOs may also help companies to future-proof their organizations from unforeseen cyber-attacks.  

Note that cyber criminals are getting smarter by the day. Therefore, companies must implement robust protocols to ward off unforeseen threats.  

Fortunately, C3PAOs don’t just focus on identifying present threats. During their routine audits, they may also point out your organization’s most vulnerable IT assets. Perhaps it’s obsolete data storage software that needs updating or upgrading. Or maybe it’s a legacy system that your business continues to hold on to at the expense of its cybersecurity.  

Whichever the case may be, a C3PAO will recommend advanced strategies you can implement to avert future cyber breaches. They may also share invaluable tips to mitigate the impact of cyber-attacks, helping your company regain operational efficiency fast if a breach occurs.  

Forestalling cyber-attacks (or effectively mitigating their impact) may ramp up productivity by minimizing operational downtimes. It can also boost your company’s reputation, giving you a competitive advantage in an era of rampant hacking activities.  

Which Companies Need CMMC Certification? 

CMMC certification is a mandatory requirement for defense contractors. According to the revamped CMMC framework, the DoD will require both prime contractors and subcontractors to comply with relevant CMMC protocols. However, as mentioned, any business can benefit from CMMC audits to understand and improve their cyber hygiene.  

C3PAOs: Redefining the CMMC Compliance Landscape 

CMMC third-party assessor organizations play an instrumental role in upholding cyber hygiene across the defense industrial base. C3PAOs help validate DoD contractors and subcontractors for CMMC compliance, minimizing cybersecurity risks across the defense supply chain. Their independent, unbiased audits also foster standardization across the DIB while enabling individual companies to bolster their cybersecurity posture.  

While the DoD accepts self-affirmations for Level 1 CMMC compliance, Level 2 certification must strictly be undertaken by a C3PAO accredited by the Cyber AB. The preferred C3PAO should also demonstrate an ability to implement tailored CMMC solutions and provide ongoing IT support to forestall future cyber breaches.