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Organizations pursuing CMMC compliance might have to work with a Certified Third Party Assessor Organization (C3PAO) as part of the certification process. Whether this is true for your organization depends on two main factors—the level of CMMC certification you're pursuing and the sensitivity of the data you handle.

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C3PAOs are still relatively new in the compliance space, so many organizations lack a clear understanding of the importance of their role in CMMC certification. This unfamiliarity might cause organizations to question the necessity of involving C3PAOs in the process without considering the benefits of having an independent, objective review of their security posture.

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In this guide, we’ll address everything you should know about C3PAOs, including:

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• What they are
• Who needs them and why
• Who can become a C3PAO
• How to find a C3PAO

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What is a C3PAO?

A C3PAO is an organization authorized by the CMMC Accreditation Body (CMMC-AB) to evaluate the level of an organization’s security program and its alignment with CMMC practices.

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The accreditation body for C3PAOs is The Cyber AB, a non-profit organization that has an exclusive contract with the Department of Defense (DoD) to test and provide certification to assessors.

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Cyber AB is the only organization with the right to provide C3PAO accreditation. When you start pursuing CMMC certification, checking for a Cyber AB certificate is imperative to ensure that your chosen assessor is authorized by the right body.

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The main purpose of C3PAOs is to provide a third-party audit of an organization’s security posture and how it relates to CMMC practices. They do this through three key activities:

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1. Interviewing staff
2. Examining evidence of compliance with the CMMC
3. Testing the implementation of the necessary CMMC practices

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{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist

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C3PAOs vs. 3PAOs

Because their roles are similar, C3PAOs are sometimes confused with 3PAOs. The key difference between the two is the certification program which they cover. The main purpose of 3PAOs is to provide audits for FedRAMP certification, while C3PAOs mainly focus on CMMC compliance.

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Both C3PAOs and 3PAOs require accreditation to perform their assessments. However, the certification body for a 3PAO isn’t the Cyber AB, but the American Association for Laboratory Accreditation (A2LA).

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This means that while both C3PAOs and 3PAOs meet the rigorous standards needed to become assessors, you’ll need to partner with a C3PAO if you’re pursuing CMMC certification.

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Who needs a C3PAO?

All organizations pursuing at least Level 2 CMMC compliance require a C3PAO as part of the process. To get a CMMC Level 2 certificate, an organization must pass one of two assessment types—a self-assessment or a C3PAO assessment. 

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The type of assessment depends on the nature of the data your organization handles and the contract requirements. If you mainly work with Federal Contract Information (FCI) and low-risk Controlled Unclassified Information (CUI), a self-assessment is usually sufficient. However, in most cases, if your organization handles CUI, you’ll need to undergo an assessment by a C3PAO for Level 2 certification.

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Both assessment types address the same 110 practices outlined by NIST SP 800-171 R2 as measurement criteria. However, C3PAO assessments provide additional security assurance since the findings come from an independent audit. 

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Even if a self-assessment may be sufficient for obtaining a CMMC Level 2 certificate, you should consider working with a C3PAO. Besides the increased confidence in your organization’s security posture, partnering with a C3PAO also offers the following benefits:

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• Guidance throughout the assessment process: C3PAOs must thoroughly understand CMMC practices to obtain accreditation, so you can leverage their expertise to clarify any potential ambiguities and streamline the compliance process.
• Objectivity: Because C3PAOs come from outside an organization to perform the assessments, they aren’t influenced by internal company policies or biases, allowing for more accurate insight into the organization's security posture.
• Potential cost-effectiveness: While involving a C3PAO presents an upfront expense, it can result in long-term savings. By guiding you through the process, C3PAOs eliminate possible guesswork and inefficiencies, reducing the need for costly remediation and resource reallocation down the line.

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{{cta_withimage22="/cta-blocks"}}  | The audit ready checklist

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Who can be a C3PAO?

Fully U.S.-owned organizations that have passed the multi-step Cyber AB accreditation process are eligible to become a C3PAO. Given the importance of C3PAOs in the CMMC certification process, the Cyber AB has stringent certification criteria. One key requirement is passing an ISO 17020 assessment to demonstrate the required tools and expertise.

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To become a C3PAO, an organization needs to take the following steps:

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1. An organization representative must fill out the C3PAO application form on the Cyber AB website. 
2. The Cyber AB conducts a risk assessment of the applicant, which includes scoring and analysis of up to 15 factors. To pass this step, applicants must achieve an overall security score of “moderate” or better. If the score indicates a risk level higher than “moderate,” the application will be sent to Cyber AB leadership for review.
3. Afterward, the Cyber AB performs a Foreign Ownership, Control, or Influence (FOCI) analysis to evaluate the risk of foreign influence on the organization. As part of this step, the Cyber AB will confirm the U.S. citizenship of company owners and review the FOCI and SF-328 forms that the applicant needs to submit.
4. As the final step of the process, the applicant must pass a CMMC Level 2 DIBCAC assessment. Once that is complete, and all administrative requirements are met, the organization receives its “Authorized C3PAO badge” from the Cyber AB.

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How to find a C3PAO

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Be mindful when selecting a C3PAO. Due to different auditor viewpoints, what might be okay for one C3PAO might not be okay for another, resulting in evidence inconsistencies and differing levels of compliance and focus. C3PAOs not being fully qualified poses risks, including failed CMMC audits, financial loss (contracts, penalties), and reputational loss due to a breach.”

Marsel Fazilov

GRC Security Program Manager, Vanta

|

LinkedIn

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Once your organization has started preparations for CMMC certification and determined you’ll need a C3PAO, you can check the official list of accredited C3PAOs on the Cyber AB Marketplace. As you evaluate your options, consider the following criteria:

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• Additional credentials: Look out for qualification badges. Certified C3PAOs will have their Cyber AB accreditation in a visible place, proving they’re authorized to conduct assessments. Also, you should check for other relevant certifications like SOC 2 or FedRAMP, which serve as proof of the C3PAO's depth of expertise.
• Expertise and track record: Find a C3PAO that understands your industry or has worked with similar organizations. For example, if you work in IT, you should hire a C3PAO with experience in the IT industry. This ensures a more relevant and thorough assessment, as the C3PAO will be familiar with the environment you operate in.
• Flexibility: Choose a C3PAO that can tailor their assessment approach to your organization’s needs, goals, and timeline. A C3PAO that can adapt to your schedule can accommodate potential delays, ensuring that the certification process runs smoothly and efficiently.
• Post-assessment services: Consider whether the C3PAO offers additional services beyond the scope of the assessment. Partnering with an assessor who assists with remediation efforts and provides regular check-ins to help ensure continuous adherence to requirements will support your organization's ongoing CMMC compliance efforts.

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How to prepare for a C3PAO assessment

After selecting a C3PAO, follow these steps to ensure your assessment goes smoothly and you avoid delays or gaps:

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1. Understand the CMMC practices: Verify the scope of your audit and whether you need to achieve a CMMC Level 2 or 3 certificate. This will help you understand what areas you'll need to focus on for the assessment.
2. Perform a pre-assessment gap analysis: Conduct your internal assessment and analysis before bringing in a C3PAO. This will highlight areas that need attention and give you a clear picture of the required workload. 
3. Remediate the identified gaps: Address any gaps identified during your internal assessment to ensure that the C3PAO audit goes smoothly.
4. Collect evidence of CMMC compliance: Maintain documentation of your compliance efforts while preparing for the CMMC audit to provide assessors with transparent insight into your organization’s current security posture.

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C3PAO assessments can be quite extensive. To ensure your organization meets CMMC practices, auditors will assess a great number of them across multiple control areas. This can increase workload and place considerable pressure on your IT and compliance teams (and other departments), leading to bottlenecks, overwork, and other inefficiencies.

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You can reduce the pressure significantly by leveraging automated compliance solutions. Compliance platforms help streamline the assessment process by optimizing workflows such as evidence collection, compliance monitoring, and report generation, allowing your compliance teams to focus on higher-priority tasks.

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{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist

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Streamline C3PAO assessments with Vanta

Vanta is a comprehensive trust management platform that streamlines CMMC compliance by providing resources and clear guidance across controls, policies, and documents for every step of the CMMC certification process, including C3PAO assessments.

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The platform’s CMMC solution offers many features that help your organization prepare for assessments efficiently and with precision, including: 

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• Out-of-the-box support for all assessment levels
• Automation of up to 50 percent of CMMC workflows through more than 375 integrations
• Automated gap assessments to focus efforts on the highest-impact areas
• Pre-mapped security controls and policy templates aligned to NIST SP 800-171 and SP 800-172
• Centralized dashboard for real-time monitoring and tracking of CMMC practices 

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Vanta can also assist you in finding a reputable C3PAO. As you prepare for your assessment, browse through Vanta’s partner network to connect with a Cyber AB-accredited C3PAO that can support your CMMC compliance efforts.

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Schedule a custom demo to see first-hand how Vanta can make preparing for assessments more efficient.

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{{cta_simple33="/cta-blocks"}} | CMMC product page

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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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