CMMC 2.0 and NIST SP 800-171 Revision 3: How Do They Align?

Publication date: Aug 09, 2023

Last Published: Aug 07, 2023

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In today’s digital age, it’s not just technology that’s advancing at a breakneck pace; the cybersecurity landscape is evolving too. In fact, the stakes are higher than ever—particularly for Department of Defense (DoD) contractors, who can’t afford even the slightest lapse in security.

Given this, staying up to speed with the latest security requirements isn’t just desirable—it’s a matter of absolute necessity. Over the years, government agencies have rolled out various cybersecurity frameworks, all intended to ensure that the standards of security enveloping government information remain as robust as possible.

Among these frameworks, two stand out prominently in the world of DoD contracting: the Cybersecurity Maturity Model Certification (CMMC) 2.0 and the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, which has recently been revised for the third time.

Both CMMC 2.0 and NIST SP 800-171 Revision 3 serve as critical bulwarks against the sophisticated threat landscape that the DoD, its contractors, and indeed the nation face. However, not all contractors fully understand how they align.

Overview of NIST SP 800-171 Revision 3

First published in 2015, NIST 800-171 provides recommended requirements for protecting the confidentiality of controlled unclassified information (CUI). It comprises 110 security controls divided into 14 control families, such as Access Control, Identification and Authentication, and System and Information Integrity.

Fast-forward to 2023, and NIST SP 800-171 has seen a significant update in its third revision.

The latest version retains the 110 security controls in number, but it significantly rearranges them by consolidating or deleting certain older controls to make room for 26 new ones.

Perhaps one of the most innovative features of Revision 3 is the introduction of organization-defined parameters (ODPs) in some security controls.

This novel approach increases flexibility, enabling federal agencies to define parameters according to their specific requirements. It’s a significant step forward, allowing customization that was lacking in the one-size-fits-all approach.

Overview of CMMC 2.0

The Cybersecurity Maturity Model Certification (CMMC) is a relatively new standard introduced in 2020 by the Department of Defense (DoD) to bolster the cybersecurity of the Defense Industrial Base (DIB). This groundbreaking certification took a significant step toward improving the security and resiliency of defense contractors and their supply chains with its clear third-party assessment requirements.

CMMC 2.0, the second version of this framework, was announced in November of 2021. In a bid to improve efficiency and ease of adoption, the DoD has streamlined the compliance levels from five to three, each aligned closely with the widely accepted NIST cybersecurity standards.

CMMC eBook

DoD Contractors Guide to CMMC Certification.

How Does CMMC 2.0 Align with NIST 800-171 Revision 3

In the journey to cybersecurity maturity, CMMC 2.0 and NIST SP 800-171 Revision 3 are far from rivals; they’re more like allies sharing a common goal. A closer look at both standards reveals their harmony and how they complement each other to fortify the defense ecosystem’s cybersecurity posture.

Let’s start with their approach to compliance. NIST 800-171, being a product of a non-regulatory agency, is a set of recommended cybersecurity practices, though the DFARS clause 252.204-7012 does mandate its implementation for contractors. However, it stops short of enforcement. That’s where CMMC 2.0 steps in—it’s more than a suggestion. It’s a stringent requirement contractors must meet to secure DoD contracts. The framework is backed by the regulatory power of the DoD, thus enforcing the implementation of NIST SP 800-171 controls.

As for the compliance requirements, the relationship between CMMC 2.0 and NIST SP 800-171 Revision 3 gets even tighter. NIST 800-171 presents a one-size-fits-all solution, requiring organizations to comply with all 110 controls, regardless of the information they handle. CMMC 2.0, on the other hand, embraces a more stratified approach. Here’s a quick rundown:

  • Level 1: Targets basic cybersecurity hygiene with 17 foundational cybersecurity practices.
  • Level 2: Maps precisely to NIST 800-171, requiring organizations to meet the same 110 controls. This level is intended for entities handling Controlled Unclassified Information (CUI).
  • Level 3: Exceeds NIST 800-171 by pulling in additional, more stringent controls from NIST SP 800-172. It’s designed for entities dealing with highly sensitive CUI or fulfilling critical defense functions.

In a nutshell, CMMC 2.0 acts like a regulatory arm for NIST SP 800-171 Revision 3, adding an extra layer of trust and assurance. It’s this shared mission of robust cybersecurity that cements the alignment between these two frameworks, making them not just allies, but indispensable teammates in the quest for a safer digital defense landscape.

Conclusion on CMMC Revision 3

In the grand scheme of cybersecurity, CMMC 2.0 and NIST SP 800-171 Revision 3 aren’t diverging paths but interconnected routes leading to a common destination—robust, resilient defense cybersecurity.

The relationship between them is synergistic, each playing its role in enhancing the cybersecurity posture of the Defense Industrial Base.

While NIST SP 800-171 sets the bar with comprehensive security controls, CMMC 2.0 ensures that bar is met and even raised. Together, they represent a formidable line of defense in an increasingly hostile cyber landscape, protecting our nation’s sensitive information against ever-evolving threats. Contact us for more information.

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