The CMMC vs. NIST 800 171 comparison is a fine line and the difference between the two needs careful consideration. As a business owner, you, your incident response team, and your organization must realize the differences between the two. The cybersecurity landscape continually shifts, so it is crucial to be up to date with DoD and federal guidelines as well as CMMC or NIST 800 171 compliance.
The main difference between NIST 800 171 and CMMC 2.0 is that NIST 800 is the standard set by the National Institute of Standards and Technology (NIST) while CMMC (Cybersecurity Maturity Model Certification) is the process to get there. And yet, the differences become more nuanced in the federal guidelines.
(There is a also difference to note between NIST 800 53 vs 800 171 – the former supports federal organizations while the latter is what we cover most with our clients: non-federal agencies and organizations.)
Enforcement of NIST 800 171 compliance began in 2018, but there was a high rate of non-compliance across the Defense Industrial Base (DIB) in subsequent years leading to vulnerabilities for sensitive information, delays or blockades in the supply chain, or risks to personnel security.
To combat that, the US Department of Defense (DoD) created the CMMC program as a tiered approach that outlines three maturity levels for obtaining cybersecurity.
Based heavily on NIST 800 171 and other cybersecurity standards, NIST CMMC compliance requirements include the documentation of procedures, management, and review of cyber events.
It requires verification by a third-party auditor to approve security standards, conduct a risk management assessment, and meet stringent CMMC compliance standards.
Comparison | CMMC | NIST 800 171 |
| Assessment Requirements | – Self-assessment for Level 1 annually – C3PAO required for Levels 2 and 3 every three years | Self-Assessment |
| Required for Federal or DoD Contracting? | Yes | Yes. NIST 800-171 is a prerequisite to comply with DoD CMMC Standards. |
| Is certification required? | Yes | None |
| Compliance Requirements | – Level 1 requires 17 practices from NIST 800-171 – Level 2 requires passing the 110 practices of NIST 800 – Level 3 aligns with 110+ practices of NIST 800-172 (i.e., CUI) and additional guidelines | – 110 security controls within 14 control groups must be assessed and implemented – Create a System Security Plan (SSP) to outline how requirements are met – Includes Plan of Action and Milestones (PoA&M) to outline how to meet requirements |
The Cyber AB is the official accreditation body for CMMC 2.0. With the March 2023 release of the White House’s new National Cybersecurity Strategy, the push for higher standards of compliance and protection against global threat actors will only increase situational awareness for cybersecurity requirements and protective measures.
The Cybersecurity Assessor and Instructor Certification Organization (CAICO) is responsible for all CMMC training and exams to ensure CMMC assessors adhere to the stringent cybersecurity practices for CMMC audits.
The Department of Defense imposed self-assessments with a points-based system for DoD contractors and subcontractors to prove compliance.
They also had to submit an SSP (System Security Plan) that detailed the business networks, processes, and security controls. Only then could contractors work with the US government and its government agencies.
For Levels 2 and 3, businesses are required to have assessments done by an authorized CMMC Third-Party Assessment Organization (C3PAO).
In contrast, organizations can conduct a NIST SP 800 171 self-assessment.
If your business wishes to collaborate with the Defense Industrial Base (DIB), you must perform the NIST 800 171 Basic Assessment and submit your score to the Supplier Performance Risk System (SPRS).
The NIST 800 171 Basic Assessment has 110 points and each practice is assigned a “weighted subtractor” value and a certain point score.
It is important to note that NIST 800 171 is not the same as the NIST Cybersecurity Framework (NIST CSF) as NIST 800 171 focuses strictly on DoD requirements whereas NIST CSF is a set of non-mandatory guidelines for DoD contractors.
To be CMMC compliant at Levels 1 and 2, you must be NIST 800 171 compliant.
CMMC Level 1 is designed t o protect FCI data. In accordance with CFR 52.204-21, 17 security controls are required to meet NIST SP 800 171 standards. Level 1 requires an annual self-assessment from Organizations Seeking Certification (OSCs), which must be approved by an OSC senior official.
To achieve cybersecurity compliance for CMMC Level 2 and protect Controlled Unclassified Information (CUI) data, businesses must adhere to all 110 practices from NIST 800 171 in accordance with DFARS (Defense Federal Acquisition Regulation Supplement) 252.204-7012.
CMMC Level 2 requires a certification assessment every three years from a C3PAO.
NIST 800 172 is still determining the final set of delta assessment practices for this level. The assessment will be conducted by the DCMA (Defense Contract Management Agency) DIBCAC (Defense Industrial Base Cybersecurity Assessment Center).
Before achieving this level, OSCs must pass Level 2 CMMC Certification from a C3PAO.
Level 3 CMMC has 130 access controls: 110 NIST 800 171 controls and 20 additional practices.
CMMC limits the number of practices that can be introduced into a Plan of Action & Milestones (POA&M).
In contrast, NIST 800 171 has no practice limitations for a POA&M.
Prior to CMMC assessments, all open items in a POA&M must be cleared by an OSC. However, a business can have a POA&M in place at the start of the assessment as specified by NIST SP 800 171 and can provide an action plan with specific dates for attaining full compliance while working with federal agencies.
The C3PAO under CMMC 2.0 issues certificates after organizations pass the assessment. There is no certificate to be issued with NIST 800 171.
CMMC compliance is still needed even if your company is NIST 800-171 compliant. This ensures you are able to work with DoD contracts and handle federal contract information.
Regarding CMMC, the DoD website details: “In accordance with DFARS 252.204-7012 (b)(ii)(D), companies can use commercial instances of cloud offerings as long as the cloud offering meets the security requirements equivalent to the FedRAMP Moderate baseline and as long as the provider meets the requirements of paragraphs (c)-(g) of the clause.”
Regarding NIST SP 800 171 to protect CUI, the rules apply when “a contractor uses an internal cloud to do his own processing related to meeting a DoD contract requirement to develop/deliver a product, i.e., as part of the solution for his internal contractor system. (Example – contractor is developing the next generation tanker, and uses his cloud (not an external cloud service provider) for the engineering design.)” ( 1 )
Businesses using cloud services need to ensure their definition of what is cloud compliance meets the more stringent requirements of federal agencies (such as timely cyber incident reporting of your DoD CUI within 72 hours of discovery).
There are many types of compliance that businesses must follow, and yet if you’re dealing with DoD contracts and information systems related to them you must adhere to NIST 800 171 compliance and CMMC standards. There is no “versus.”
To reiterate, NIST 800 171 compliance is used for non-government agencies to protect CUI data.
To get the full risk assessment from cyber threats beyond the basic cyber hygiene for your business (especially when dealing with CMMC Levels 2 or 3), you must look to a third-party assessor to ensure proper cybersecurity requirements are met.
CMMC compliance will be mandatory for all defense contractors by 2026.
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1 – “Frequently Asked Questions (FAQs) regarding the implementation of DFARS Subpart 204.73 and PGI Subpart 204.73, DFARS Subpart 239.76 and PGI Subpart 239.76.” dodprocurementtoolbox.com, Nov. 23, 2021