The U.S. Department of Defense (DoD) has published the final rule for the Cybersecurity Maturity Model Certification (CMMC) 2.0—a development that will impact various aspects of cybersecurity compliance, including third-party assessments, cloud service provider requirements, and documentation standards.
The regulation, outlined in CFR 32, is set to go into effect on December 16, 2024, and introduces significant changes for defense contractors that handle Controlled Unclassified Information (CUI). The new CMMC framework aims to enhance cybersecurity within the Defense Industrial Base (DIB) by mandating compliance with NIST SP 800-171 controls.
One of the key changes under the CMMC 2.0 framework is the introduction of mandatory third-party assessments for organizations seeking CMMC Level 2 certification. These assessments will be conducted by Certified Third-Party Assessment Organizations (C3PAOs), ensuring compliance with the 110 controls outlined in NIST SP 800-171 Rev2. A minimum score of 88 is required for certification, with limited flexibility for deferring certain controls through Plans of Action and Milestones (POAMs).
The phased rollout of CMMC contractual requirements begins in Q2 2025, with a full implementation plan that extends through four phases, ending in 2028.
For organizations relying on cloud service providers (CSPs) or external service providers (ESPs), the CMMC Final Rule introduces specific compliance obligations. CSPs used to store, process, or transmit CUI must meet FedRAMP Moderate Baseline Equivalent requirements, or they must have an official Authorization to Operate (ATO).
Similarly, ESPs that provide security services like multi-factor authentication or antivirus software will fall within the organization’s compliance boundary and will be subject to the same cybersecurity assessments. These measures aim to secure not only the prime contractors but also their supply chains, ensuring the protection of sensitive data at all levels.
The CMMC framework also emphasizes the importance of robust documentation, requiring organizations to develop and maintain System Security Plans (SSPs) and Customer Responsibility Matrices (CRMs). These documents serve as proof of compliance and outline shared responsibilities between organizations and their service providers. Any deferred controls, managed through POAMs, must be fully implemented within 180 days of certification.
This strict adherence to cybersecurity controls is part of a broader effort to ensure that CUI remains secure across the entire defense supply chain.
The use of biometric technologies is likely to play a significant role in organizations’ efforts to meet CMMC requirements, particularly in the areas of access control and identity verification. Biometric systems can strengthen security measures by providing multi-factor authentication capabilities, and are poised to help contractors meet NIST SP 800-171’s access control requirements by ensuring that only authorized personnel can access CUI, reducing the risk of unauthorized data breaches.
Moreover, as the DoD increasingly integrates advanced biometric solutions into its cybersecurity strategies, contractors may be required to adopt similar technologies to align with CMMC standards.
The CMMC Final Rule marks a significant shift in how the DoD will enforce cybersecurity standards among its contractors. By mandating third-party assessments, requiring compliance with NIST SP 800-171, and emphasizing the role of cloud and external service providers, the rule aims to improve the overall security of the defense supply chain. Organizations that handle CUI must be prepared to integrate advanced security measures, such as biometrics, to meet the new requirements.
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October 23, 2024 – by the ID Tech Editorial Team
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