Are You Ready for a C3PAO?

Companies that are part of the Defense Industrial Base (DIB) will soon have to comply with the Cybersecurity Maturity Model Certification (CMMC) to do business with any Department of Defense contracting office. Compliance certification is managed by the CMMC Accreditation Body (CMMC-AB), which also certifies the individuals and organizations you may work with on the road to compliance and certification, including a C3PAO.    

What is a C3PAO?

A CMMC Third-Party Assessor Organization (C3PAO) is an organization authorized by the CMMC-AB to manage CMMC assessors responsible for executing compliance assessments of Defense Contractors who qualify. C3PAOs determine whether or not your business is satisfying the requirements to become compliant, meaning you adhere to all of the requirements for CMMC Level 1, CMCC Level 2 or CMCC Level 3 or higher. 

To get compliant, you can self-assess and manage your own compliance, or you can work with a Registered Provider Organization (RPO) like Hyper Vigilance to put the processes and controls in place necessary for compliance. RPOs may provide advice, consulting, recommendations or implementation assistance.  

Does my business need a C3PAO to be CMMC Certified?

Yes. Only a C3PAO can conduct a Certified CMMC Assessment and issue a certification of compliance. To become licensed by the CMMC-AB, C3PAOs pay fees, carry insurance, undergo background checks, and obtain their own CMMC Level 3 certification and meet other requirements.   

C3PAOs are authorized to manage the compliance assessment process. They must employ or contract with at least one Certified CMMC Assessor (CCA), who performs the assessments and, in turn, may be supported by Certified CMMC Professionals (CCPs). Both CCAs and CCPs undergo training by licensed training providers and are certified by the CMMC-AB. The CMMC-AB provides standards and methods that the CCAs follow.

Is there a cost for a CMMC certification?

Yes. Assessment fees are determined by the C3PAO and will vary by certification tier level. Chief Information Security Officer (CISO) Katie Arrington, at the Office of the Under Secretary of Defense Acquisition & Sustainment, estimated that a company should expect to pay between $3,000 and $5,000 for CMMC Level 1 certification. Moreover, companies without an existing NIST 800-171 compliance program can expect to incur significant costs to achieve compliance with CMMC Level 3. On a positive note, the DoD has determined that cybersecurity is an allowable cost that can be billed to the DoD. 

How do I find a C3PAO?

The CMMC-AB maintains a Marketplace that serves the entire CMMC ecosystem, including Organizations Seeking Certification (OSCs)—that would be you. Currently, the Marketplace lists more than 100 candidate companies who have completed applications to be a C3PAO and are pending their own CMMC Level 3 certification. The Marketplace also maintains listings of licensed training publishers, training providers, assessors, registered practitioners and registered providers. 

What should I do to prepare for a C3PAO?

First, familiarize yourself with the requirements for each CMMC level and determine which is necessary for your business. Then evaluate your security posture against the compliance requirements, identifying which controls you meet, what practices you follow, and what gaps you need to address to become compliant. You can do this evaluation internally, or recruit the help of an RPO like Hyper Vigilance to inspect your compliance status and recommend a game plan for addressing any gaps.

When should I get started?

Although the CMMC doesn’t become fully effective until October 1, 2025, certification will be required to bid on contracts that start on or after that date, and certification requirements are already being added to DoD RFPs for both prime contractors and subcontractors. Depending on where your business currently stands, preparing for a CMMC Level 3 audit can take a considerable amount of time, so it’s not too early to get started now.    

Start your compliance journey with Hyper Vigilance

At Hyper Vigilance, our goal is to make getting CMMC compliant as simple and accessible as possible with our straightforward pricing model and full-service compliance management solutions. An easy way to get started is to find out where you stand today with a compliance readiness inspection. Get in touch with us to begin your journey to CMMC certification.

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