As we are aware, entities in the DoD supply chain must endure rigorous assessments as part of the CMMC accreditation process. The companies themselves neither conduct these audits nor are they guided by the CMMC Accreditation Body (CMMC-AB). Instead, Certified Third-Party Assessment Organizations conduct them (C3PAOs).
Contractors accustomed to other standards, such as FedRAMP, will understand the notion of a 3PAO in CMMC security. These security businesses are certified in a certain framework and educated to undertake assessments within that framework, as determined by a governing body. As a result, a C3PAO will analyze your IT architecture depending on your desired Maturity Level criteria, run tests linked to those criteria, and provide a summary to address the replacement of systems that do not meet minimal standards, all in accordance with CMMC laws. If your audit is successful, the C3PAO will also provide you with the complete document for your certification.
If you are pursuing CMMC accreditation, your C3PAO will most likely be the nearest organization to you.
What Does it Take to Become a C3PAO?
The CMMC-AB stipulates that any company seeking C3PAO status must fulfill several requirements.
All C3PAOs are required to:
Complete the CMMC Level 3 evaluation.
- Have you conducted any third-party cloud service inspections to fulfill FedRAMP specifications?
- Necessitate NAC, DHS Suitability, or other DoD clearance certification for assessment team members.
- Incorporate liability insurance for “Errors and Omissions” and “Cybersecurity Breaches” as a baseline. The CMMC-AB is the insured party.
- All organizations must do Dun & Bradstreet background checks with a DUNS number.
- Demonstrate a business that is entirely owned and run by Americans.
- Obtain accreditation for ISO 9001, ISO 27001, and CMMI Maturity Level 2 or 3
- What Should I Think About When Creating a C3PAO?
There are a few major skills and factors to consider while adopting a C3PAO:
Certifications that are correct: Your C3PAO should have the appropriate certifications to fulfill your CMMC Maturity Level requirements. C3PAOs will be at least Level 3 in giving evaluations and reports, but they must reach or exceed your required level.
The CMMC-AB Marketplace site has the following listings: Clearly said, if you are unable to locate a security firm.
While your C3PAO won’t be able to advise you on your impending audit (see below), they will be able to give important insight and remedy guidance during the accreditation process. As a result, a company with knowledge in the industry may make identifying and resolving gaps easier.
A History of Working with Companies That Are Similar to Yours: C3PAOs aren’t all made equal. While one organization may have substantial expertise with various infrastructures, it is beneficial if your C3PAO has a general understanding of your IT and business objectives.
Is there a difference between a C3PAO and an RPO?
Another CMMC regulation classification appears to perform the same function as a C3PAO. For CMMC audit preparation, a Registered Provider Organization (RPO) acts as a certified, professional consultant. The CMMC-AB continues to teach and certify RPOs, and a C3PAO can also hold RPO certification.
A C3PAO, on the other hand, cannot act as your certification RPO. Because of potential conflicts, if you have an entity working with you as your RPO before the CMMC audit, they cannot also function as your C3PAO (despite if they are qualified as a C3PAO).
On the other hand, an RPO may act as a consultant before and throughout your CMMC audit to assist you.