What is a C3PAO? Essential Partners for CMMC Success

Updated on May 8, 2024 by Mike Mariano

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What is a C3PAO in CMMC?

C3PAO in Cybersecurity Maturity Model Certification (CMMC) is an organization recognized by the CMMC Accreditation Body (CMMC-AB) to assess the cybersecurity practices of a contractor. A C3PAO is officially allowed to grant certification to a contractor based on their control’s level of adherence to CMMC 2.0 requirements. 

The acronym C3PAO stands for Certified Third Party Assessor Organization. Accredited C3PAOs are listed on an official roster of The Cyber AB Marketplace and are certified CMMC assessors. In other words, they are considered certified CMMC professionals.

Cybersecurity companies with C3PAO status are recognized to have passed a set of strict requirements and examinations, including stringent training programs.

The Roles of C3PAO

Among many other roles, a C3PAO is mainly responsible for carrying out CMMC 2.0 standards and the DoD’s requirements. 

Here are some of the specific roles of a C3PAO:

1. Conduct CMMC assessments, including an organizational background check.
2. Identify an organization’s level of preparedness.
3. Guide organizations through the certification process.
4. Verification of compliance with CMMC 2.0.
5. Assess the incident response of the organization. 
6. Provide certification to assessed organizations. 
7. Liaison of DoD for compliance.

Defense contractors and subcontractors engaging with federal contract information (FCI) and/or controlled unclassified information (CUI) and collaborating with the DoD must undergo CMMC assessments corresponding to their assigned Level. This requirement will mean coordinating with a highly reliable C3PAO. 

How Does an Organization Become a C3PAO Candidate?

Organizations aiming to be accredited CMMC C3PAO must comply with a set of requirements divided into three phases. Each phase may consist of easy tasks, such as filling out forms and comprehensive exams and assessments to be carried out by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).

One of the critical requirements to become a C3PAO is for the candidate to pass a CMMC 2.0 Level 3 assessment themselves. 

Below are the requirements for becoming a C3PAO candidate from the Cyber AB website:

Phase 1

To become a C3PAO candidate, a company representative must submit an application. Afterward, candidates are reviewed through various stages. In assessing each applicant’s risks, Cyber AB collaborates with Dunn and Bradstreet (D&N) to analyze and score around 15 factors. Applicants must acquire at least a “Moderate” level of risk overall to proceed further in this procedure.

Phase 2

After completing the application, they must pass a Foreign Ownership Control or Influence (FOCI) analysis by submitting the FOCI form included in their application and an SF-328. The evaluation also involves interviewing the firm’s top managers and verifying that they are American citizens.
Once passed, the C3PAO applicant is proclaimed as a C3PAO Candidate. Subsequently, if the Cyber AB concludes that Candidate C3PAO is ready for assessment by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC), its information will be sent to the DoD CMMC PMO to schedule CMMC Level 2 Assessment.

Phase 3

C3PAOs are given the authority to conduct assessments once they achieve CMMC Level 2, fulfill all the administrative requirements such as proof of insurance, dispute resolution process, etc., and obtain the “Authorized C3PAO badge” from Cyber AB.

Qualities of a Credible C3PAO for CMMC Compliance

The most critical qualities of a C3PAO that every service organization would expect are the assessor’s expertise, training, customer service, and thoroughness. These qualities set good CMMC assessors apart from the others. 

The roll-out of the CMMC 2.0 rule is anticipated to start in the first quarter of 2025. However, as early as now, aspiring organizations are already applying for C3PAO candidacy.

Hone your team’s skills and invest in the right qualities, such as the following:

1. Knowledge of the CMMC 2.0 rule. Every qualified C3PAO is expected to have a full understanding of CMMC 2.0. What would set a great C3PAO apart is their knowledge of adopting the regulations to different organizational setups. This quality requires deep knowledge of the CMMC certification framework.
2. Great communication skills. The CMMC assessment is a two-way process. Cooperation from both ends is required. As such, the C3PAO must be able to effectively communicate the requirements and explain its strategy in detail to the organization. The ability to work with industry professionals is a critical quality for any certified assessor. 
3. Comprehensiveness in reports. C3PAOs are expected to have excellent writing skills when it comes to drawing up reports. Assessment deliverables must clearly reflect the current status of an organization’s security system with adjacent solutions where needed. Reports must not create confusion or misrepresentation. 

Selecting a C3PAO demands careful evaluation from organizations. Certifications, service offerings, experience, and customer support are critical considerations. A competent C3PAO should hold appropriate certifications, provide comprehensive services, boast relevant experience, and offer top-notch customer support. 

Get CMMC Compliant With AWA – a C3PAO Candidate

Despite the delays in implementing the CMMC 2.0, the AWA group has gotten ahead of the game by becoming a C3PAO candidate. AWA is at the forefront of conducting expert assessments and ensuring that organizations comply with CMMC regulations. 

Our team is composed of IT experts with decades of experience in ensuring compliance with some of the most stringent regulations, such as PCI DSS, SOC 2, HITRUST CSF, ISO, and NIST. 

Entrust your CMMC compliance with experts from AWA. Contact us today!

About The Author

Mike Mariano

Michael is the Chief Information Security Officer at IS Partners as well as the leader of the penetration testing practice for AWA International. Michael has 15+ years’ experience in internal IT operations with 7 years of being involved in various levels of IT auditing with experience with PCI DSS, SOC 2, HITRUST CSF, Risk Assessments and experience working with Security Frameworks (such as ISO and NIST). Michael has worked with/at companies from 10 to 50,000 employees in size. Prior to joining IS Partners, Michael worked as the IT Operations Manager at AVASEK an MSP IS Security firm where he managed a team of six technicians to service 1500 client endpoints as well as the firm's Cloud Hosting Solution. while at AVASEK, Michael also performed gap assessments against HIPPA and NIST Security Frameworks and was a member of the incident response team. Michael’s specialties are IT Security and IT Management. He is experienced in performing security Risk Assessments, enforcing security policies, handling confidential information, deploying and administering network and application security systems, administrating SaaS products, Active Directory (AD), firewalls, routers, and VPN. Michael is HITRUST CCSFP and AWS CP Certified and has maintained various CompTIA Certifications over his career. He is currently working to achieve his GIAC GWAP and OSCP Certification in 2020.