What Does It Mean To Be C3PAO Certified?

The Cybersecurity Maturity Model Certification (CMMC) is set to become mandatory for all Department of Defense (DoD) contractors by 2025. To achieve CMMC compliance, organizations must work with a Certified Third-Party Assessment Organization (C3PAO).

In this article, we explain what a C3PAO is, the role it plays in the CMMC certification process, and why partnering with one is critical for DoD contractors.

 

What Is a C3PAO?

As the U.S. Department of Defense (DoD) moves away from NIST self-certification, organizations now require a Certified Third-Party Assessor Organization (C3PAO) to achieve CMMC compliance.

A C3PAO is an accredited third-party auditor authorized to perform CMMC assessments and grant certification. Before the CMMC, organizations could work with the DoD or other members of the Defense Industrial Base (DIB) if they were NIST 800-171 compliant.

NIST 800-171 relied on self-certification, meaning organizations could internally or externally audit themselves to demonstrate adherence to security controls. While sufficient at the time, this approach lacked consistent oversight and accountability.

To strengthen cybersecurity across the DIB, the DoD introduced the CMMC framework and the role of the C3PAO. By requiring assessments from accredited third parties, the DoD ensures that organizations maintain robust security practices and adds an extra layer of accountability.

What Is the CMMC?

To understand the role of a C3PAO, it helps to first get a clear overview of the Cybersecurity Maturity Model Certification (CMMC).

The CMMC builds on the NIST 800-171 framework, which established baseline security standards for organizations in the Defense Industrial Base (DIB). Unlike NIST 800-171, which was primarily self-assessed, the CMMC introduces tiered maturity levels ranging from 1 to 5. These levels expand on existing controls to ensure organizations implement a robust cybersecurity program.

Your organization’s required maturity level depends on the type and amount of Controlled Unclassified Information (CUI) it handles. The maturity levels are cumulative, achieving level 4, for example, requires compliance with all previous levels.

Whether an organization meets the required maturity level is determined by an external assessor: the C3PAO.

While this article focuses on the role of the C3PAO, you can consult our guide [link] for a beginner-friendly explanation of the CMMC and its maturity levels.

Do I Need to Be CMMC Certified?

Understanding whether your organization needs CMMC certification is essential, whether you are pursuing certification yourself or planning to become a C3PAO.

Not every organization in the Defense Industrial Base (DIB) supply chain automatically requires CMMC certification. Certification is specifically required for organizations that handle federal contracts or process Controlled Unclassified Information (CUI).

For such organizations, CMMC Level 1 is the minimum requirement for handling federal contract information, with higher maturity levels required depending on the type and sensitivity of CUI processed.

 

What Are the Responsibilities of a C3PAO?

A C3PAO is responsible for assessing how effectively an organization has implemented the CMMC framework. Their role is crucial in maintaining high cybersecurity standards across the Defense Industrial Base (DIB).

While CMMC accreditation is becoming a recognized service in the cybersecurity industry, the broader goal is to strengthen national cyber defense. Recent incidents, such as the SolarWinds breach, highlight why the DoD and U.S. government are emphasizing accountability in the private sector.

The C3PAO’s primary responsibility is to grant CMMC certification. However, there is often an opportunity for a collaborative partnership between the C3PAO and the organization. In these cases, the C3PAO may assist with preparation, implementation, and institutionalization of CMMC controls, though this varies by assessor.

Regardless of partnership, organizations seeking certification should aim to implement CMMC controls thoroughly before engaging a C3PAO. A well-prepared organization ensures a smoother assessment and increases the likelihood of successful certification

C3PAO Accreditation

The C3PAO accreditation process is still in the early stages, but the DoD has established an accreditation board to oversee the program (details in the next section).

As the CMMC framework is gradually phased in, compliance initially applies only to prime contractors. Over the next five years, the DoD plans to extend CMMC requirements to all contractors, with full implementation expected by 2025.

C3PAO accreditation, however, will roll out sooner, allowing organizations to develop their assessment and implementation capabilities ahead of the full compliance deadline. This early rollout helps prepare both C3PAOs and the Defense Industrial Base (DIB) for smoother certification processes.

Who Grants C3PAO Accreditation?

C3PAO accreditation is granted by the CMMC Accreditation Board (CMMC-AB). It’s important to note that accreditation is awarded to individual assessors who aim to become certified CMMC practitioners—not to the organization itself.

A C3PAO is an organization that employs these certified assessors or includes them as part of its structure. These assessors are the ones who conduct CMMC audits and help organizations implement the framework effectively.

In other words, while the C3PAO as an organization coordinates and supports the assessment process, it is the certified assessors within the C3PAO who carry out evaluations and develop compliance strategies for their clients.

The C3PAO Accreditation Process

To become a C3PAO assessor, the first step is to register with the CMMC Accreditation Board (CMMC-AB). After registration, candidates must complete an introductory CMMC online training course and pass a commercial background check.

The final prerequisite is signing the CMMC-AB professional code of conduct. Once these steps are completed, you can officially begin your journey as a CMMC practitioner.

It’s important to note that CMMC practitioners must be affiliated with a Registered Provider Organization (RPO), such as RSI Security. The CMMC ecosystem consists of organizations seeking certification, RPOs, and certified training providers—together forming the CMMC marketplace. This platform helps connect seekers with qualified providers.

While certified training providers support education and preparation, all testing and official certification are conducted exclusively by the CMMC-AB.

Can My Business Become a C3PAO?

Not all businesses are eligible to become a C3PAO. There are several prerequisites that must be met.

1. Citizenship Requirements: All assessors must be U.S. citizens. While a foreign organization can theoretically be a C3PAO, its assessors must be citizens of the country where the organization is based. Additionally, C3PAOs outside the U.S. must be in countries with bilateral agreements concerning the CMMC. At the time of writing, no such agreements exist, meaning all C3PAOs are currently U.S.-based.
2. CMMC Compliance: Any C3PAO must itself be CMMC Level 3 certified. Level 3 certification ensures that the organization has the same security protections as Controlled Unclassified Information (CUI). C3PAOs must also secure all assessment data. Cloud storage is permitted if the provider is FedRAMP authorized; otherwise, an independent assessment must be conducted and submitted to the Defense Contract Management Agency (DCMA).
3. ISO 17020 Accreditation: C3PAOs must achieve ISO 17020 accreditation, the international standard for organizations performing inspections. This accreditation confirms that the organization can conduct audits consistently, efficiently, and impartially, critical for maintaining the integrity of CMMC assessments. The CMMC-AB allows a 27-month grace period from registration to attain ISO 17020 compliance.
4. Financial Requirements: There is an initial $1,000 application fee and a $200 activation fee upon acceptance. These fees are separate from CMMC Level 3 assessment costs, which the CMMC-AB currently estimates at $750.

By meeting these requirements, citizenship, CMMC Level 3 certification, ISO 17020 accreditation, and financial obligations., an organization can become a C3PAO and join the CMMC ecosystem as a certified assessor provider.

How to Hire a C3PAO

The CMMC Accreditation Board (CMMC-AB) has collaborated with the DoD to establish a CMMC ecosystem, which includes a marketplace for C3PAOs. This platform allows organizations to connect with Registered Provider Organizations (RPOs), C3PAO candidates awaiting assessment, and individual registered practitioners.

At the time of writing, there are no officially authorized C3PAOs. However, organizations can still use the marketplace to identify qualified candidates and providers.

Hiring a C3PAO works similarly to engaging any audit or inspection service. Both parties should agree on the scope of the audit, which is determined by the CMMC maturity level required by the DoD.

Pricing considerations depend on several factors:

• Maturity level required: Higher levels require more extensive assessment.
• Size of the organization being assessed.
• Service provider selected.
• Assessor expertise and experience.
  

By understanding these factors, organizations can select the most suitable C3PAO to achieve their required level of CMMC compliance efficiently and effectively.

Preparing for a CMMC Assessment

Before scheduling a formal assessment, organizations seeking certification must prepare thoroughly. As discussed earlier, a C3PAO audits your cybersecurity infrastructure and verifies that your organization has achieved the required CMMC maturity level.

It’s important to note that the C3PAO cannot provide consulting services to the organizations they are assessing. However, organizations can engage a Registered Provider Organization (RPO), such as RSI Security, to prepare in advance. This preparation strengthens your chances of achieving certification.

Preparing for a CMMC assessment typically involves three key steps:

1. Gap Analysis: A gap analysis identifies where your organization falls short of CMMC requirements. Many service providers offer gap analysis for frameworks like GDPR, CCPA, or ISO standards. This analysis highlights deficiencies and provides actionable solutions to address them.
2. Strategy and Implementation Planning: After completing the gap analysis, a provider develops a strategy to implement and institutionalize necessary controls. For CMMC, this ensures your organization meets the required maturity level effectively.
3.  Remaining Agile: Organizations must stay flexible leading up to the assessment. While CMMC controls themselves may not change, business environments do. Service providers can assist throughout the preparation period, and even after, to ensure that changes do not compromise your required maturity level.

Recap: Quick-Start Guide for C3PAO and CMMC Certification

The CMMC 2025 transition is approaching fast. All organizations in the Defense Industrial Base (DIB) and DoD supply chain will be required to obtain certification. Today, C3PAOs are the only entities authorized to award certification, making preparation for assessments essential.

Here’s a C3PAO Quick-Start Guide:

FAQ	Answer
Does my business require CMMC?	If your organization is in the DIB and holds federal contracts with the DoD, CMMC certification is required.
Who grants CMMC accreditation?	CMMC accreditation is provided exclusively by a certified third-party assessment organization (C3PAO).
Who certifies the C3PAO?	C3PAOs are authorized and overseen by the CMMC Accreditation Board (CMMC-AB).
Can my business become a C3PAO?	If your organization meets the requirements outlined in this article, ISO 17020 compliant, pays the application fees, U.S.-based, and passes a CMMC Level 3 assessment, your business can become a C3PAO.

How RSI Security Can Help:
RSI Security is a Registered Provider Organization (RPO) with deep expertise in preparing organizations for CMMC assessments. We guide you through gap analysis, implementation planning, and readiness strategies to increase your chances of certification and ensure compliance with C3PAO standards.

Stay Ahead of the Curve with RSI Security

RSI Security is an authorized Registered Provider Organization (RPO) that can help you navigate the CMMC ecosystem and select the right C3PAO for your organization. While currently only prime DoD contractors are required to have CMMC certification, full compliance across the Defense Industrial Base (DIB) is inevitable.

Stay one step ahead by preparing early with RSI Security. Leverage our industry expertise to strengthen your cybersecurity infrastructure and ensure a smooth CMMC maturity assessment.

Contact RSI Security, you can confidently approach CMMC certification and work effectively with your C3PAO to secure your organization’s future in the DoD supply chain.

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