What’s a C3PAO? Hint – Not a “Star Wars” Character!

What’s New (Updated for C3PAO Assessments & Enforcement)

This blog has been updated to reflect the CMMC Final Rule (32 CFR Part 170), which has been fully enforceable since November 10, 2025. CMMC Level 2 and Level 3 requirements now appear in active DoD solicitations, and most organizations handling CUI must demonstrate compliance through a C3PAO assessment when required by the contract. References to CMMC being “upcoming” or “future” have been updated to reflect active enforcement.

Understanding CMMC Requirements in Today’s Compliance Environment

The Defense Industrial Base (DIB) serves as the supplier community for the U.S. Department of Defense (DoD). Any company in the DIB should have the Cybersecurity Maturity Model Certification (CMMC) on its radar. CMMC certification is no longer a future requirement—it is now a contractual requirement when specified in DoD solicitations.

What Is CMMC 2.0 Compliance?

CMMC 2.0 compliance represents a security framework designed to protect sensitive but unclassified data from theft that places U.S. national security at risk. Examples of this data include Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). CMMC 2.0 compliance is now a contractual requirement under the Final Rule for applicable DoD solicitations.

The DoD created CMMC because existing cybersecurity contractual requirements to protect data like CUI have proven ineffective. Those requirements apply to all DoD prime contractors and their subcontractor supply chains who store, process, transmit or otherwise handle CUI. These organizations must fully address the 110 security controls defined in the National Institute of Standards and Technology’s Special Publication 800-171 (NIST SP 800-171).

Under the Final Rule, entities may only self-assess when permitted by the solicitation; most organizations handling CUI must undergo a C3PAO assessment. Those that do not meet all 110 controls can submit a Plan of Action and Milestones (POA&M) to get there.

Unfortunately, the current system simply does not work. CUI continues to be compromised at an alarming rate. POA&Ms do not get fully executed. And businesses believe they possess stronger cybersecurity maturity than reality dictates. Audits conducted by the DoD have consistently demonstrated contractors have overestimated their NIST SP 800-171 compliance postures. Thus, the need for CMMC certification.

What Makes CMMC 2.0 Different?

CMMC 2.0 consists of three Maturity Levels (ML). ML1 applies to all members of the DIB and focuses on keeping FCI safe. Upwards of 80,000 companies will be subject to ML2, which trains its sights on CUI protection. ML2 demands full compliance with NIST SP 800-171. Only a small fraction of the DIB (likely less than one percent) will fall under ML3 and additional security requirements above and beyond NIST SP 800-171.

Yes, ML2 sounds a lot like the current underperforming regime. However, it differs in two important ways.

The first involves POA&Ms. They won’t be allowed for every NIST SP 800-171 control as they are today. They must be closed within 180 days. And only organizations close to full CMMC 2.0 compliance will even be given the POA&M option.

The second relates to who performs the NIST SP 800-171 assessment and attests to the result. Most companies that handle CUI must now rely on a C3PAO assessment to determine CMMC Level 2 compliance when required by contract. Instead, they will need to rely on an independent party to determine CMMC compliance and eligibility for a CMMC ML2 accreditation.

What is CMMC 2.0 Certification? Enter C3PAO

Businesses seeking CMMC ML2 accreditation will not be able to engage just any auditor to conduct the NIST SP 800-171 171/CMMC self-assessment. Instead, they will have to work with an authorized CMMC 3rd Party Assessment Organization (C3PAO) on their CMMC assessment.

C3PAOs receive their authorizations from The CMMC Accreditation Body (The Cyber AB). The DoD contracted with The Cyber AB, a non-profit, to oversee the CMMC ecosystem that consists of C3PAOs, training organizations, individual CMMC assessors, and others.

C3PAOs must complete a rigorous process to achieve authorization from The Cyber AB. The process includes risk analyses and background checks that if favorable allow the company to become a candidate C3PAO. Candidates subsequently must pass a CMMC ML2 assessment executed by the DoD to achieve authorized status.

Authorized C3PAOs and their teams of CMMC-certified professionals and assessors possess a deep understanding of the 110 NIST SP 800-171 controls. They bring an accurate and unbiased eye to determine a DIB firm’s cybersecurity maturity, compliance with the controls, qualification for POA&M, and ultimately CMMC ML2 accreditation. Now that CMMC certification is mandatory for applicable Level 2 and Level 3 contracts, they will be required to undergo a triennial CMMC assessment by a C3PAO.

The DoD believes the C3PAOs’ independent assessments that serve as a gateway to accreditation will improve the cybersecurity posture and compliance of the entire DIB. As a result, FCI and CUI will be harder to compromise and U.S national security will be strengthened.

Act Now: CMMC Enforcement Is Underway

As of November 10, 2025, CMMC 2.0 requirements are officially in effect, marking the beginning of the Department of Defense’s three-year phased rollout. Initial DoD solicitations are now including CMMC clauses, and contractors must be prepared to demonstrate compliance, or risk being ineligible for award.

If your organization is unsure whether it is ready for a C3PAO assessment, or if documentation, evidence, or scoping gaps remain, now is the time to strengthen your compliance approach. Explore tools that help defense contractors prepare for Level 2 and Level 3 assessments, centralize evidence, and reduce readiness risk under the Final Rule.

Even with enforcement underway, preparation remains critical. Achieving full NIST SP 800-171 compliance and passing a C3PAO assessment can still take 12 to 18 months, depending on the organization’s cybersecurity maturity and resource availability.

The Cyber AB’s network of authorized C3PAOs remains limited—fewer than 100 accredited organizations are currently serving a market of approximately 80,000 DIB contractors expected to require Level 2 certification. This means assessment backlogs are likely to persist well into 2026.

To maintain eligibility and avoid delays, organizations should:

• Validate compliance against NIST SP 800-171 Rev. 2 or Rev. 3 (when applicable).
• Update your System Security Plan (SSP) and confirm any POA&M items are actively remediated.
• Engage a C3PAO early to schedule a readiness or certification assessment.
• Leverage compliance tools like Exostar’s CMMC Ready Suite™ to streamline documentation and security control management.

CMMC enforcement has begun but achieving and maintaining certification is an ongoing process. Taking action now ensures your organization stays competitive and compliant as the rollout continues through 2028.

May the force be with you.

To understand how Exostar’s CMMC Ready Suite™ can help you get through the CMMC 2.0 compliance maze visit our page and set up a free demo and a time to talk to one of our specialists.

What You Should Really Do Now

To comply with the Final Rule, organizations should confirm whether Level 2 or Level 3 applies to their current or upcoming solicitations, validate NIST SP 800-171 implementation, and ensure SSPs and POA&Ms are accurate and current. If a C3PAO assessment is required, engage an authorized C3PAO early to avoid scheduling delays. Confirm SPRS submissions are accurate and supported by evidence, and use the CMMC Levels Quiz to verify your required assessment path.