Cybersecurity Maturity Model Certification (CMMC) and the Federal Risk and Authorization Management Program (FedRAMP) are comprehensive security programs required for organizations that wish to pursue government contracts.
Both frameworks aim to safeguard the sensitive data of government agencies, as well as their contractors and subcontractors. Despite the shared goal, they have notable differences you should understand before starting your compliance activities.
In this CMMC vs. FedRAMP comparison, we’ll outline those differences and explain how to choose the applicable program. We’ll also discuss how these frameworks overlap and what this means for your compliance posture.
What is CMMC?
CMMC is a cybersecurity certification program introduced and enforced by the U.S. Department of Defense (DoD). Its main goal is to protect the two types of data that the DoD might share with non-government entities:
- Federal Contract Information (FCI): Information provided by the government as part of a contract
- Controlled Unclassified Information (CUI): Sensitive information that requires protection but isn’t classified
The program came into effect in late 2024, and its implementation is currently underway. The DoD plans on enforcing the CMMC in the following four phases:
- Phase 1 (by mid-2025): Organizations will be required to complete self-assessments for Level 1 and 2 solicitations
- Phase 2 (by mid-2026): Organizations must obtain certificates for Level 2 contracts
- Phase 3 (by mid-2027): Requirements for Level 3 certifications will be included in select contracts
- Phase 4 (by mid-2028): All solicitations and contracts will include CMMC certification as a prerequisite for contract award
This gradual rollout gives organizations time to understand the specific CMMC practices that apply to their organization and implement the corresponding ones effectively.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
What is FedRAMP?
FedRAMP is a risk management program that standardizes the security assessment, authorization, and continuous monitoring procedures for cloud products and services involved in the work performed for government agencies. The program’s goal is to ensure the secure adoption of cloud-based services by all federal agencies.
The first version of FedRAMP was introduced in 2011 by the General Services Administration (GSA). Due to the increased adoption of cloud-based services among government agencies, the program underwent major changes in 2022 with the signing of the FedRAMP Authorization Act.
One key change was the formation of the FedRAMP Board, which replaced the Joint Authorization Board (JAB). The FedRAMP Board now oversees the program’s adoption, aiming to accelerate it across federal agencies.
Much like CMMC, FedRAMP strives to create a secure and transparent cloud environment, and the two frameworks share a few implementation specifics.
Similarities between FedRAMP and CMMC
The key similarity between CMMC and FedRAMP is a tiered attestation structure. Both frameworks offer three levels that in-scope organizations must choose from, with the main difference being the selection criteria.
FedRAMP’s levels are based on the impact that a security incident could have on government data. The categorization is based on NIST’s Federal Information Processing Standard (FIPS), which defines three levels of impact:
- Low: Loss of data confidentiality, integrity, and availability could only have a limited impact on an agency’s operations
- Moderate: Security incidents could cause significant operational damage or harm to individuals
- High: An organization’s assets, operations, and individuals could face severe or catastrophic damage as a result of an incident
Each impact level corresponds with specific controls that an in-scope organization must implement to prevent security incidents.
CMMC defines certification levels according to the specific data a contractor or subcontractor can access, store, or share. The levels are as follows:
- Level 1 (Foundational): Organizations that handle FCI
- Level 2 (Advanced): Organizations that handle FCI and non-critical CUI
- Level 3 (Expert): Organizations that handle critical CUI
Another notable similarity is the mandatory nature of both frameworks—all in-scope organizations must comply to pursue and maintain government contracts.
{{cta_withimage22="/cta-blocks"}} | The audit ready checklist
4 differences between FedRAMP and CMMC
Despite their similarities, FedRAMP and CMMC differ in four important aspects:
- Applicability
- Scope
- Controls
- Attestation
Below, we’ll cover each difference in more detail.
1. Applicability
CMMC focuses specifically on organizations within the Defense Industrial Base (DIB), so it’s applicable to those that aim to work with the DoD. With the exception of providers of commercial off-the-shelf (COTS) items, all DoD contractors and subcontractors must achieve CMMC certification to work with the department.
In contrast, FedRAMP is only aimed at cloud service providers (CSPs). It applies to any CSP that seeks to provide services to any federal agency without being restricted to one particular branch of the government.
Because FedRAMP's and CMMC's practices don’t overlap significantly, these two frameworks are not interchangeable. This means that if a CSP intends to work with the DoD, it might need to achieve compliance with both frameworks.
2. Scope
FedRAMP encompasses a CSP’s systems, networks, and devices through which any federal data flows. CSPs must define a so-called Authorization Boundary, which includes all components of their IT systems that must be authorized for operation by the relevant body.
Besides specific federal information, all associated data and metadata should be accounted for in the Authorization Boundary. This includes:
- Logs
- Audit trails
- Vulnerability reports
CMMC has a narrower scope—it only encompasses the elements of an organization’s infrastructure that process, store, or transmit FCI and CUI. Both information types are classified as not intended for public release, though CUI explicitly requires robust protection. The following table outlines some examples of FCI and CUI:
Because of its broader scope, FedRAMP might be more challenging to implement than CMMC due to numerous controls. It might also be more costly due to the need for FedRAMP-approved software.
For example, you typically can’t use the commercial version of Okta within a FedRAMP environment—you have to use the government version, which is significantly more expensive. Combined with the potential IT infrastructure changes, these costs can add up quickly.
3. Controls
The number of CMMC practices you need to meet depends on your chosen certification level:
- Level 1: 15 practices aligned to FAR Clause 52.204-21
- Level 2: 110 practices based on NIST SP 800-171 R2
- Level 3: 110 Level 2 practices + 24 practices based on NIST SP 800-172
Because of its broader scope, FedRAMP has more controls, which are based on NIST SP 800-53 R5. The latest version of FedRAMP has the following number of controls for different impact levels:
- Low: 158 controls
- Moderate: 325 controls
- High: 412 controls
While compliance with both programs can be challenging due to extensive security workflows, FedRAMP tends to be particularly demanding (especially for small organizations with a restricted budget and personnel).
Neither framework evolves rapidly, so we can expect their controls and requirements to remain relatively stable in the foreseeable future. Still, the attestation and assessment processes might become more rigorous down the line.
4. Attestation
CMMC is a certifiable program, so successful completion results in a certificate you can use to demonstrate compliance. To obtain it, your organization will need to undergo one of the three assessment types:
- A self-assessment for Level 1 and a limited number of Level 2 certificates. This level focuses on basic cybersecurity hygiene. For Level 1, a score is not required.
- A CMMC Third Party Assessor Organization (C3PAO) assessment for most Level 2 certificates. Level 2 represents intermediate cybersecurity hygiene and organizations must achieve a minimum passing score of 88.
- A Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) assessment is required for all Level 3 certificates. Level 3 is the most rigorous CMMC level, and certification represents good cybersecurity hygiene. Level 3 requires a prerequisite Level 2 score of 110.
Level 1 certificates are valid for one year, while Levels 2 and 3 offer a three-year certification. Still, you must submit annual compliance affirmations for all levels to maintain your certificate.
Meanwhile, FedRAMP is an authorization program—achieving compliance results in an Authorization to Operate (ATO), which allows you to work with any federal agency. Obtaining an ATO requires an audit by a 3PAO, which is similar to a C3PAO but focused specifically on cloud services.
Once obtained, your ATO will be valid indefinitely. Still, the FedRAMP’s continuous monitoring requirement calls for annual assessments to ensure ongoing compliance.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
Should you comply with FedRAMP or CMMC?
“
The answer to this question will depend on the type of contract an organization is seeking (DoD vs. non-DoD), infrastructure (on-premise, cloud, or hybrid), and timelines. It's important to pay attention to the requirements of an organization's contracts and speak to their agency contact first."
If you must comply with both, prioritizing FedRAMP might be wise because it’s likely a prerequisite for CMMC anyway (if your infrastructure involves the cloud). Still, you should verify this with your prospective (or current) DoD customer or agency before deciding.
Regardless of your chosen framework, achieving compliance can be challenging without proper guidance and streamlined workflows. To complete your selected program effectively and efficiently, you should support compliance with a dedicated software solution.
Vanta: Your CMMC and FedRAMP compliance partner
Vanta is a comprehensive trust management platform that provides clear guidance for CMMC compliance, along with tools that accelerate your path to certification and reduce time spent on manual work across controls, policies, and documents.
Vanta does this by automating up to 50 percent of CMMC workflows with features like:
- Out-of-the-box support for all certification levels
- Automated evidence collection supported by 375+ integrations
- Pre-mapped security controls aligned to NIST SP 800-171 and NIST SP 800-172
- Automated gap assessments
- Built-in resources like policy templates
- Centralized tracking and monitoring of CMMC practices through a real-time dashboard
To help you reduce duplicative workflows, Vanta cross-references your existing controls with over 35 standards and frameworks, including FedRAMP.
Organizations can choose their C3PAO for CMMC Level 2 assessments (and consequently Level 3). You can also leverage Vanta’s partner network to find reputable auditors who’ll support you throughout the process.
Schedule a custom demo of Vanta’s CMMC solution for a live overview of its capabilities.
{{cta_simple33="/cta-blocks"}} | CMMC product page
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
CMMC vs. FedRAMP: Similarities and differences
Looking to automate up to 50% of the work for CMMC?
Cybersecurity Maturity Model Certification (CMMC) and the Federal Risk and Authorization Management Program (FedRAMP) are comprehensive security programs required for organizations that wish to pursue government contracts.
Both frameworks aim to safeguard the sensitive data of government agencies, as well as their contractors and subcontractors. Despite the shared goal, they have notable differences you should understand before starting your compliance activities.
In this CMMC vs. FedRAMP comparison, we’ll outline those differences and explain how to choose the applicable program. We’ll also discuss how these frameworks overlap and what this means for your compliance posture.
What is CMMC?
CMMC is a cybersecurity certification program introduced and enforced by the U.S. Department of Defense (DoD). Its main goal is to protect the two types of data that the DoD might share with non-government entities:
- Federal Contract Information (FCI): Information provided by the government as part of a contract
- Controlled Unclassified Information (CUI): Sensitive information that requires protection but isn’t classified
The program came into effect in late 2024, and its implementation is currently underway. The DoD plans on enforcing the CMMC in the following four phases:
- Phase 1 (by mid-2025): Organizations will be required to complete self-assessments for Level 1 and 2 solicitations
- Phase 2 (by mid-2026): Organizations must obtain certificates for Level 2 contracts
- Phase 3 (by mid-2027): Requirements for Level 3 certifications will be included in select contracts
- Phase 4 (by mid-2028): All solicitations and contracts will include CMMC certification as a prerequisite for contract award
This gradual rollout gives organizations time to understand the specific CMMC practices that apply to their organization and implement the corresponding ones effectively.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
What is FedRAMP?
FedRAMP is a risk management program that standardizes the security assessment, authorization, and continuous monitoring procedures for cloud products and services involved in the work performed for government agencies. The program’s goal is to ensure the secure adoption of cloud-based services by all federal agencies.
The first version of FedRAMP was introduced in 2011 by the General Services Administration (GSA). Due to the increased adoption of cloud-based services among government agencies, the program underwent major changes in 2022 with the signing of the FedRAMP Authorization Act.
One key change was the formation of the FedRAMP Board, which replaced the Joint Authorization Board (JAB). The FedRAMP Board now oversees the program’s adoption, aiming to accelerate it across federal agencies.
Much like CMMC, FedRAMP strives to create a secure and transparent cloud environment, and the two frameworks share a few implementation specifics.
Similarities between FedRAMP and CMMC
The key similarity between CMMC and FedRAMP is a tiered attestation structure. Both frameworks offer three levels that in-scope organizations must choose from, with the main difference being the selection criteria.
FedRAMP’s levels are based on the impact that a security incident could have on government data. The categorization is based on NIST’s Federal Information Processing Standard (FIPS), which defines three levels of impact:
- Low: Loss of data confidentiality, integrity, and availability could only have a limited impact on an agency’s operations
- Moderate: Security incidents could cause significant operational damage or harm to individuals
- High: An organization’s assets, operations, and individuals could face severe or catastrophic damage as a result of an incident
Each impact level corresponds with specific controls that an in-scope organization must implement to prevent security incidents.
CMMC defines certification levels according to the specific data a contractor or subcontractor can access, store, or share. The levels are as follows:
- Level 1 (Foundational): Organizations that handle FCI
- Level 2 (Advanced): Organizations that handle FCI and non-critical CUI
- Level 3 (Expert): Organizations that handle critical CUI
Another notable similarity is the mandatory nature of both frameworks—all in-scope organizations must comply to pursue and maintain government contracts.
{{cta_withimage22="/cta-blocks"}} | The audit ready checklist
4 differences between FedRAMP and CMMC
Despite their similarities, FedRAMP and CMMC differ in four important aspects:
- Applicability
- Scope
- Controls
- Attestation
Below, we’ll cover each difference in more detail.
1. Applicability
CMMC focuses specifically on organizations within the Defense Industrial Base (DIB), so it’s applicable to those that aim to work with the DoD. With the exception of providers of commercial off-the-shelf (COTS) items, all DoD contractors and subcontractors must achieve CMMC certification to work with the department.
In contrast, FedRAMP is only aimed at cloud service providers (CSPs). It applies to any CSP that seeks to provide services to any federal agency without being restricted to one particular branch of the government.
Because FedRAMP's and CMMC's practices don’t overlap significantly, these two frameworks are not interchangeable. This means that if a CSP intends to work with the DoD, it might need to achieve compliance with both frameworks.
2. Scope
FedRAMP encompasses a CSP’s systems, networks, and devices through which any federal data flows. CSPs must define a so-called Authorization Boundary, which includes all components of their IT systems that must be authorized for operation by the relevant body.
Besides specific federal information, all associated data and metadata should be accounted for in the Authorization Boundary. This includes:
- Logs
- Audit trails
- Vulnerability reports
CMMC has a narrower scope—it only encompasses the elements of an organization’s infrastructure that process, store, or transmit FCI and CUI. Both information types are classified as not intended for public release, though CUI explicitly requires robust protection. The following table outlines some examples of FCI and CUI:
Because of its broader scope, FedRAMP might be more challenging to implement than CMMC due to numerous controls. It might also be more costly due to the need for FedRAMP-approved software.
For example, you typically can’t use the commercial version of Okta within a FedRAMP environment—you have to use the government version, which is significantly more expensive. Combined with the potential IT infrastructure changes, these costs can add up quickly.
3. Controls
The number of CMMC practices you need to meet depends on your chosen certification level:
- Level 1: 15 practices aligned to FAR Clause 52.204-21
- Level 2: 110 practices based on NIST SP 800-171 R2
- Level 3: 110 Level 2 practices + 24 practices based on NIST SP 800-172
Because of its broader scope, FedRAMP has more controls, which are based on NIST SP 800-53 R5. The latest version of FedRAMP has the following number of controls for different impact levels:
- Low: 158 controls
- Moderate: 325 controls
- High: 412 controls
While compliance with both programs can be challenging due to extensive security workflows, FedRAMP tends to be particularly demanding (especially for small organizations with a restricted budget and personnel).
Neither framework evolves rapidly, so we can expect their controls and requirements to remain relatively stable in the foreseeable future. Still, the attestation and assessment processes might become more rigorous down the line.
4. Attestation
CMMC is a certifiable program, so successful completion results in a certificate you can use to demonstrate compliance. To obtain it, your organization will need to undergo one of the three assessment types:
- A self-assessment for Level 1 and a limited number of Level 2 certificates. This level focuses on basic cybersecurity hygiene. For Level 1, a score is not required.
- A CMMC Third Party Assessor Organization (C3PAO) assessment for most Level 2 certificates. Level 2 represents intermediate cybersecurity hygiene and organizations must achieve a minimum passing score of 88.
- A Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) assessment is required for all Level 3 certificates. Level 3 is the most rigorous CMMC level, and certification represents good cybersecurity hygiene. Level 3 requires a prerequisite Level 2 score of 110.
Level 1 certificates are valid for one year, while Levels 2 and 3 offer a three-year certification. Still, you must submit annual compliance affirmations for all levels to maintain your certificate.
Meanwhile, FedRAMP is an authorization program—achieving compliance results in an Authorization to Operate (ATO), which allows you to work with any federal agency. Obtaining an ATO requires an audit by a 3PAO, which is similar to a C3PAO but focused specifically on cloud services.
Once obtained, your ATO will be valid indefinitely. Still, the FedRAMP’s continuous monitoring requirement calls for annual assessments to ensure ongoing compliance.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
Should you comply with FedRAMP or CMMC?
“
The answer to this question will depend on the type of contract an organization is seeking (DoD vs. non-DoD), infrastructure (on-premise, cloud, or hybrid), and timelines. It's important to pay attention to the requirements of an organization's contracts and speak to their agency contact first."
If you must comply with both, prioritizing FedRAMP might be wise because it’s likely a prerequisite for CMMC anyway (if your infrastructure involves the cloud). Still, you should verify this with your prospective (or current) DoD customer or agency before deciding.
Regardless of your chosen framework, achieving compliance can be challenging without proper guidance and streamlined workflows. To complete your selected program effectively and efficiently, you should support compliance with a dedicated software solution.
Vanta: Your CMMC and FedRAMP compliance partner
Vanta is a comprehensive trust management platform that provides clear guidance for CMMC compliance, along with tools that accelerate your path to certification and reduce time spent on manual work across controls, policies, and documents.
Vanta does this by automating up to 50 percent of CMMC workflows with features like:
- Out-of-the-box support for all certification levels
- Automated evidence collection supported by 375+ integrations
- Pre-mapped security controls aligned to NIST SP 800-171 and NIST SP 800-172
- Automated gap assessments
- Built-in resources like policy templates
- Centralized tracking and monitoring of CMMC practices through a real-time dashboard
To help you reduce duplicative workflows, Vanta cross-references your existing controls with over 35 standards and frameworks, including FedRAMP.
Organizations can choose their C3PAO for CMMC Level 2 assessments (and consequently Level 3). You can also leverage Vanta’s partner network to find reputable auditors who’ll support you throughout the process.
Schedule a custom demo of Vanta’s CMMC solution for a live overview of its capabilities.
{{cta_simple33="/cta-blocks"}} | CMMC product page
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
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