CMMC vs FedRAMP: Which One Applies to You (and When You Need Both)

Last reviewed: June 2026 · Clause version reviewed: 32 CFR Part 170 (eff. Dec 16, 2024); DFARS 252.204-7012; OMB M-24-15

If you’ve heard “CMMC” and “FedRAMP” thrown around like they’re the same thing — or like one cancels out the other — you’re in good company, and the confusion gets expensive fast. So here’s the bottom line on CMMC vs FedRAMP: they are not interchangeable, and one does not replace the other. CMMC (Cybersecurity Maturity Model Certification) applies to defense contractors that handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). FedRAMP (Federal Risk and Authorization Management Program) applies to cloud services used by federal agencies. Most companies need only one. Both come into play in two situations: when a DoD contractor uses a cloud service to handle CUI, and when a single organization wears two hats — a defense contractor anda cloud provider selling to the government. One of these blindsides people. We’ll get to it.

Who this page is for: DoD prime contractors, subcontractors, MSPs, MSSPs, SaaS vendors, FSOs, IT directors, compliance leads, and small-business owners trying to figure out whether CMMC, FedRAMP, or both apply before they spend six figures on the wrong thing.

What this page is not:a generic “what is CMMC” explainer, a step-by-step FedRAMP authorization guide, or a provider ranking. It answers the upstream question everyone actually has — is this a CMMC problem, a FedRAMP problem, or both? — and points you to the right next move.

CMMC vs FedRAMP at a glance

That table answers the surface question. The rest of this page answers the one underneath it: which of these is actually your problem?

What’s the difference between CMMC and FedRAMP?

CMMC certifies the contractor; FedRAMP authorizes the cloud service. CMMC is the Department of Defense’s program requiring contractors that handle FCI or CUI to implement and prove cybersecurity controls. FedRAMP is the federal program that authorizes a cloud service offering for agency use. CMMC follows your company and the system it assesses. FedRAMP follows the cloud product.

The cleanest way to keep them straight: CMMC is about you, the contractor. FedRAMP is about a cloud service.

CMMC is contractor-scope driven. Under 32 CFR Part 170 — the CMMC Program Rule, effective December 16, 2024 — CMMC applies to DoD contractors and subcontractors whose covered information systems process, store, or transmit FCI or CUI in the performance of a contract. It has three levels. Level 1 maps to the 15 basic safeguarding requirements in FAR 52.204-21 and is met by an annual self-assessment. Level 2 maps to the 110 security requirements in NIST SP 800-171 Revision 2, organized into 14 control families, and is met by either a self-assessment or a certification assessment by a C3PAO (Certified Third-Party Assessment Organization), depending on what the contract requires. Level 3 adds 24 selected requirements from NIST SP 800-172 and is assessed by the government — specifically DCMA’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). One precision point that trips readers up: a CMMC status attaches to the assessed system or scope and is recorded in SPRS — it is not a blanket, company-wide stamp.

And a detail we see wrong on competing pages: CMMC Level 1 is 15 requirements, not 17.That number comes straight from FAR 52.204-21(b)(1). If a page tells you Level 1 has 17 practices, it’s running on pre-final-rule language.

FedRAMP is cloud-service-offering driven.FedRAMP standardizes how a cloud service is security-assessed, authorized, and continuously monitored for federal agency use. It’s built on NIST SP 800-53 Revision 5, with Low, Moderate, and High baselines assigned by FIPS 199 impact categorization, and a 3PAO (Third-Party Assessment Organization) does the independent assessment. The whole point is “authorize once, use many times” — one agency authorizes a cloud service, and others can reuse that work. Per OMB Memo M-24-15, agencies must obtain and maintain a FedRAMP authorization for a cloud product or service when it falls within FedRAMP scope; it does not apply to every internet service an agency happens to use.

They’re cousins, not twins. Both descend from NIST. FedRAMP uses NIST SP 800-53 directly; CMMC Level 2 uses NIST SP 800-171 Rev. 2, which is itself a CUI-focused subset derived from 800-53. That shared DNA creates real overlap in the controls — but, and this matters, overlap is not reciprocity. Holding one does not earn you the other.

The overlap exists for one reason: contractors use the cloud.When a DoD contractor uses an external cloud service to store, process, or transmit CUI, the two worlds touch. They do not merge. That single sentence is the source of nearly every “CMMC vs FedRAMP” headache, so we built the next section around it.

Do you need CMMC, FedRAMP, or both?

You need CMMC if your DoD contract requires protection of FCI or CUI on your systems. You need FedRAMP if you offer a cloud service used by a federal agency. You need both in two cases: you’re a DoD contractor using a cloud to handle CUI (CMMC for your company, plus a FedRAMP Moderate cloud), or you’re one organization that is both a defense contractor and a cloud provider to the government — two separate hats, two separate obligations. What you need is set by what you do and what your contract says — not by a checklist.

Start with one question, depending on who you are:

• Defense contractor? Start with your contract clause and your data flow. Where does FCI or CUI actually live and move?
• Cloud or SaaS provider? Start with who buys your service and whose information it handles.
• MSP, MSSP, GRC platform, or enclave provider? Start with function: do you process CUI, handle only Security Protection Data, or operate as a cloud service provider?

Then find your row. This is the asset we built that you can’t get from a single competing page — we combined the contract role, the data handled, the cloud-service role, the evidence to gather, the provider category to talk to, the common wrong move, and the primary source in one place. (One term you’ll see below: CDI, or covered defense information — the DFARS 252.204-7012 term that, for DoD contractor cloud use, overlaps heavily with CUI.)

The CMMC vs FedRAMP Applicability Matrix

One honest pointer before you go further. If you only sell cloud to civilianagencies and never touch a DoD contract or CUI, this site isn’t built for you — your path is FedRAMP, and you should start at fedramp.gov and with a FedRAMP 3PAO. We focus on the CMMC and DIB side. We’d rather send you to the right place than waste your time.

When does CMMC actually require FedRAMP?

CMMC doesn’t make every system FedRAMP-bound. The trigger appears when a DoD contractor uses an external cloud service provider to store, process, or transmit CUI. Per DFARS 252.204-7012, the contractor must require and ensure that cloud meets security requirements equivalent to the FedRAMP Moderate baseline. A cloud that is already FedRAMP Moderate authorized satisfies that CSP requirement automatically — though your own environment stays in scope.

Here’s the rule in plain English, and it’s the one most people get tangled in.

A file server in your office holding CUI is a CMMC and NIST SP 800-171 problem. The moment that CUI moves into a cloud service — email, file sharing, CAD, ERP, ticketing, backup — it becomes a CMMC and a FedRAMP-evidence problem. The clause that governs this is DFARS 252.204-7012, and it has been in DoD contracts since 2016. Paragraph (b)(2)(ii)(D) says that if a contractor uses an external cloud service provider to store, process, or transmit covered defense information, the contractor must “require and ensure” that the provider meets security requirements equivalent to the FedRAMP Moderate baseline, and complies with the clause’s cyber-incident-reporting obligations in paragraphs (c) through (g).

The CMMC Program Rule reinforces this and, helpfully, draws a bright line on who owns the risk. Per 32 CFR Part 170, if you’re using a FedRAMP Authorized cloud at the Moderate baseline or higher, you are not responsible for the cloud provider’s own compliance — the authorization speaks for itself. But if the cloud is not FedRAMP authorized, you become responsible for determining whether it meets FedRAMP Moderate equivalency.That’s a meaningful shift in burden, and it’s the difference between “check the Marketplace listing and move on” and “collect, review, and stand behind an evidence package.” Either way, the cloud’s status never covers your tenant configuration, endpoints, identity, documentation, or the controls you own.

A few clarifications that save real money:

• Encryption alone doesn’t get you out of it.You can’t just encrypt CUI, drop it in any commercial cloud, and call it compliant. DoD’s CMMC FAQ states a non-FedRAMP-Moderate cloud service offering cannot store encrypted CUI for contract performance unless the provider meets FedRAMP Moderate–equivalent requirements. The encryption helps you protect the data; it does not remove the cloud requirement.
• Not every tool is a cloud-CUI problem. A security tool that touches only Security Protection Data — logs, alerts, telemetry — and never handles CUI is treated under 32 CFR Part 170 as a Security Protection Asset. It can still be in scopefor your assessment, but it doesn’t automatically drag a FedRAMP requirement along with it. This is why a CMMC Level 2 environment doesn’t require every single tool to be FedRAMP authorized — a point a lot of vendors conveniently blur.
• This is why GCC High, GovCloud, and Azure Government exist.Standard Microsoft 365 Commercial does not meet the requirement for CUI. Microsoft built GCC High specifically to satisfy these DoD and FedRAMP obligations, and AWS GovCloud and Azure Government exist for similar reasons. But product-family names aren’t enough — before you put CUI anywhere, verify the exactoffering’s status and class on the FedRAMP Marketplace, confirm it covers the services where CUI will live, and get the CRM.

And the stakes here aren’t theoretical. In September 2025, the Department of Justice’s Civil Cyber-Fraud Initiative settled with Georgia Tech Research Corporation for $875,000 over alleged False Claims Act violations on Air Force and DARPA contracts. The government’s allegations: no system security plan for the lab in question, antivirus tools that weren’t installed or run, and a summary-level cybersecurity assessment score submitted to DoD that was allegedly based on a “fictitious” environment rather than the actual systems handling the data. Those are allegations, resolved without a determination of liability — but the message to contractors is plain. Getting your security plan, your controls, and your reported scores wrong isn’t just an assessment delay; it can become a legal exposure.

Does FedRAMP replace CMMC?

No. FedRAMP can support the cloud layer of your CMMC environment, but it does not certify your company, your endpoints, your tenant configuration, your identity controls, your documentation, or your full assessment scope. A FedRAMP-authorized cloud is an input to your CMMC evidence — not a substitute for your CMMC status.

This is the most common and most expensive misread on the topic, so let’s be blunt: a FedRAMP authorization is not a CMMC certificate. It is one piece of cloud evidence sitting inside a much larger assessment boundary.

A FedRAMP-authorized cloud can let you inherita set of controls — the provider’s data-center security, infrastructure controls, certain platform capabilities, and a Marketplace-backed authorization you can point to. That’s genuinely valuable. It shrinks your work. But inheritance has limits, and the limits are exactly where contractors fail.

The shared-responsibility piece deserves emphasis. Every cloud authorization comes with a Customer Responsibility Matrix — the list of controls the cloud provider handles versus the controls youstill own. FedRAMP covers the provider’s side. The CRM is where your side lives, and a C3PAO will look right at it. Treating the cloud’s authorization as the whole story is how organizations walk into an assessment confident and walk out with findings.

The one-line version, worth taping to your monitor: FedRAMP is not your CMMC certificate; it’s one piece of cloud evidence inside your CMMC assessment boundary.

Is FedRAMP Moderate enough for CMMC Level 2?

For a DoD contractor using an external cloud to handle CUI, FedRAMP Moderate authorization — or DoD-recognized Moderate equivalency — is the baseline most often discussed in the CMMC and DFARS context. FedRAMP High may be required for separate contractual, agency, mission, or export-control reasons, but High is not the universal CMMC Level 2 requirement. The contract and the data decide.

We want to be careful here, because this is a place where well-meaning pages overstate things. The named baseline for cloud handling of CUI in the CMMC and DFARS conversation is FedRAMP Moderate or equivalent. Some environments end up on FedRAMP High— because of a specific agency requirement, the sensitivity of the data, export-control considerations, or a customer mandate. But you should not assume FedRAMP High is automatically required for CMMC Level 2. It usually isn’t.

Before you accept any vendor’s “FedRAMP Moderate” claim, verify these six things:

1. Is the exact product or service offering listed — not just the parent company?
2. Is that offering Moderate or higher (or the equivalent Certification Class — see the next section)?
3. Is it the same environment and version you’ll actually use?
4. Does the listing cover the services where CUI will live?
5. Will the provider give you a Customer Responsibility Matrix?
6. Is your assessor asking for Marketplace proof, a CRM, SSP references, or an equivalency Body of Evidence — and can the vendor produce them?

If a vendor can’t answer those crisply, that’s your signal to slow down and verify before you commit budget or data.

What is FedRAMP Moderate equivalency, and how is it different from “authorized”?

FedRAMP Moderate equivalency is a DoD pathway for a cloud service that lacks a FedRAMP authorization to demonstrate it meets equivalent FedRAMP Moderate security for DoD contractor use. It does not confer FedRAMP authorization, and it shifts evidence-validation responsibility onto the contractor.“Authorized” is a status on the FedRAMP Marketplace; “equivalent” is an evidence package you have to review and stand behind.

This distinction is where a lot of money and a lot of timeline get lost, so here’s exactly how it works.

On December 21, 2023, the DoD Chief Information Officer issued a memo titled FedRAMP Moderate Equivalency for Cloud Service Providers’ Cloud Service Offerings — and made it effective immediately. Per that memo and the assessors who work with it daily, a cloud service offering is FedRAMP Moderate equivalent only if it meets all three of these:

1. It achieves 100% of the FedRAMP Moderate security control baseline (no open gaps at the conclusion of the assessment).
2. That compliance is assessed by a FedRAMP-recognized 3PAO.
3. The provider produces a Body of Evidence (BoE) and presents it to the contractor.

Now the part competitors muddle: a cloud with a valid FedRAMP Moderate (or higher) authorization listed on the Marketplace automatically satisfies DFARS 252.204-7012.There’s no separate Body of Evidence for you to validate, and no need for a C3PAO or DIBCAC to re-check it. The equivalency pathway exists only for clouds that have not completed full FedRAMP authorization but still want to serve the DIB.

If a vendor claims equivalency, ask for the Body of Evidenceand confirm it includes: a FedRAMP-recognized 3PAO’s involvement, the System Security Plan (SSP), the Security Assessment Plan (SAP) and Report (SAR), the Plan of Action and Milestones (POA&M), continuous-monitoring materials, the Customer Responsibility Matrix, an incident-response plan, and confirmation that the 100% compliance bar was met at the conclusion of the 3PAO assessment.

Here’s the honest catch — the one trade-off we won’t paper over. FedRAMP equivalency is legitimate, and for plenty of contractors it’s the right call. But it is genuinely harder for a buyer to verifythan a live FedRAMP Marketplace authorization. With an authorized cloud, you confirm a listing and you’re done. With equivalency, you’re relying on a Body of Evidence you have to actually review — and if your CMMC clock is already running, that review can create more friction than you budgeted for. That doesn’t make equivalency wrong. It means you get the evidence package reviewed beforeyour assessment is scheduled, not during it. And if your timeline is tight and you’d rather not carry that verification burden at all, that’s a strong reason to look at a FedRAMP-authorized CUI enclave or a GCC High environment instead — same protection, far less evidence ambiguity.

Is FedRAMP changing? FedRAMP 20x, the 2026 rules, and why old “CMMC vs FedRAMP” guides are wrong

Yes — significantly. FedRAMP is modernizing through “FedRAMP 20x” and the 2026 Consolidated Rules (CR26), and it is renaming a FedRAMP authorization to “FedRAMP Certification” with Certification Classes A–D. The Joint Authorization Board that older comparison pages still reference has been dissolved.The DFARS still says “FedRAMP Moderate,” and Class C maps to that historical Moderate baseline.

If you’ve read a few “CMMC vs FedRAMP” articles and noticed them mentioning the Joint Authorization Board (JAB)as a way to get FedRAMP authorized — stop trusting those pages on the FedRAMP side. The JAB was dissolved and replaced by the FedRAMP Board under the FedRAMP Authorization Act, and OMB Memo M-24-15 (2024) set the current policy. Authorization now runs through an Agency path or a Program path. A surprising number of ranking pages still describe a “JAB P-ATO” route that no longer exists.

What’s actually happening now, confirmed in FedRAMP’s own public notices (NTC-0004, NTC-0007, NTC-0008, published February–March 2026):

• A FedRAMP authorization is being renamed “FedRAMP Certification” (or “FedRAMP Certified”). FedRAMP says this is to stop the constant confusion between a FedRAMP authorization (done by FedRAMP) and an authorization to operate (done by an agency).
• Impact levels are becoming Certification Classes. Class A is a time-limited pilot tier; Class B maps to the historical Low/Li-SaaS baselines, Class C maps to the historical Moderate baseline, and Class D maps to the historical High baseline.
• The Consolidated Rules for 2026 (CR26) will formalize all of this. FedRAMP says CR26 will publish by the end of June 2026, apply to all cloud providers by December 31, 2026, and stay in effect through December 31, 2028.
• FedRAMP Ready retires July 28, 2026.No FedRAMP Ready submissions will be accepted after that date; existing ones convert to a Class A path or become “Legacy FedRAMP Ready.”
• FedRAMP 20xis the engine behind the speed: machine-readable evidence (OSCAL) and Key Security Indicators (KSIs) instead of long control-by-control narratives. FedRAMP’s stated goal is to make agency authorization decisions simple enough to complete “within days or weeks.”

Here’s the terminology snapshot — verified June 2026:

Two things this means for the CMMC vs FedRAMP question. First, a FedRAMP Certification (or any FedRAMP authorization, by any name) is not a government-wide authorization to operate. FedRAMP is explicit: an agency still has to review the package and make its own risk decision under the NIST Risk Management Framework. Second, there is no FedRAMP-to-CMMC reciprocity— and FedRAMP has been clear that even its new path for leveraging external frameworks (starting with SOC 2 Type II) grants no reciprocity. Do not treat a FedRAMP status as a substitute for CMMC Level 2 evidence. Because the labels are mid-transition, verify any cloud’s status and class against the FedRAMP Marketplace at the time you make your decision.

3PAO vs C3PAO: same four letters, different jobs

A 3PAO assesses cloud services for FedRAMP. A C3PAO assesses defense contractors for CMMC.They’re accredited by different bodies and produce different outputs. Some firms hold both authorizations — which is exactly why the acronyms get confused.

Same overlapping letters, completely different programs. And yes, several large firms are botha 3PAO and a C3PAO — useful if you genuinely need both kinds of work, but it’s a big reason the terms blur. When a vendor says “we’re an authorized assessor,” ask: authorized for which program?

A note on independence, because it directly affects your money: under the Cyber AB’s Code of Professional Conduct, a C3PAO that provided consulting, implementation, or readiness/remediation services to an organization generally cannot perform that organization’s Level 2 certification assessment for three years.Don’t let a single vendor sell you “we’ll fix you and then certify you” as one tidy package — that conflict is prohibited, not a preference. Use an RPO or RP (Registered Provider Organization / Registered Practitioner) for readiness, and a separate C3PAO for the assessment.

How do MSPs, MSSPs, GRC platforms, and CUI enclaves fit?

Provider category matters, but function matters more.An MSP isn’t automatically a cloud service provider, an MSSP handling only Security Protection Data isn’t automatically storing CUI, and a CUI enclave can shrink your scope without erasing your CMMC responsibilities. The right question is always: what does this provider process, store, transmit, protect, administer, or resell?

Two function-not-label distinctions that come straight from DoD guidance:

• An MSP is not automatically a CSP. Per the DoD CMMC FAQ, if your customer licenses or subscribes to the cloud and the MSP only administers the tenant, the MSP may not be the cloud service provider. But if the MSP contracts for the cloud service, modifies it, and resells it as its own offering, it may itself be treated as a CSP — which pulls FedRAMP/equivalency into the picture. Check the contract relationship before you label anyone.
• An External Service Provider that handles only Security Protection Data can still be in scopeas a Security Protection Asset under 32 CFR Part 170 — even without touching CUI. “We don’t store your CUI” is not the same as “we’re out of scope.” Document it in the SSP and the service description either way.

Before you buy anything: the pre-purchase checklist

Before you buy a tool, a consulting package, or an assessment, map your contract clause, your FCI/CUI/CDI flow, your system boundary, your external providers, your cloud offerings, and your assessment type. The expensive mistake is buying a FedRAMP-labeled tool or scheduling a C3PAO before you know which environment is actually in scope.

Work these seven steps first:

1. Identify whether the contract involves FCI, CUI, CDI, or none. (A DFARS 252.204-7012 reference is a strong signal CUI is in play; FAR 52.204-21 signals FCI.)
2. Find the clause or flow-down language — and look for DFARS 252.204-7025, the solicitation provision that puts you on notice of the required CMMC level before award.
3. Determine the CMMC level and assessment type the contract requires (Level 1 self, Level 2 self, Level 2 C3PAO, or Level 3 DIBCAC).
4. Map where CUI is processed, stored, or transmitted.
5. List every CSP, ESP, MSP, MSSP, GRC platform, and enclave in the environment.
6. Request FedRAMP Marketplace proof or an equivalency Body of Evidence for any cloud handling CUI/CDI.
7. Decide what you actually need: readiness help, implementation, evidence software, enclave strategy, or a formal assessment.

And before you sign with any vendor, ask them this — copy it straight into your notes:

• Are you a CSP, ESP, MSP, MSSP, GRC platform, CUI enclave, RPO/RP, C3PAO, or FedRAMP 3PAO?
• Will you process, store, or transmit our CUI? Or only Security Protection Data?
• Is your exact offering FedRAMP Moderate authorized, FedRAMP High authorized (Class C/D), or claiming Moderate equivalency?
• Can you provide a Customer Responsibility Matrix?
• Can your evidence be used by a C3PAO or DIBCAC assessor?
• Are you independent from the organization that would perform our certification assessment?
• Are you making a certification claim, an authorization claim, or a readiness claim?

That last question is the tell. Vendors blur “certified,” “authorized,” and “ready” constantly. Make them pick a word.

The most common CMMC vs FedRAMP mistakes

The costliest CMMC vs FedRAMP mistakes come from treating labels as outcomes— “FedRAMP cloud” as CMMC compliance, “CMMC ready” as FedRAMP authorization, “GCC High” as a finished assessment, or “encrypted CUI” as out of scope. Assessors look at data flow, scope, evidence, and responsibilities — not marketing.

Mistake 1 — “We bought FedRAMP, so we’re CMMC compliant.” FedRAMP supports the cloud layer of your evidence. CMMC still evaluates your whole assessment scope — endpoints, identity, documentation, and the controls you own in the CRM.

Mistake 2 — “We’re CMMC Level 2, so our SaaS is FedRAMP-ready.” A CMMC status doesn’t authorize a cloud service offering. Those are different programs with different assessors.

Mistake 3 — “The parent company is FedRAMP authorized.” Verify the specific offering, environment, version, and impact level/class on the FedRAMP Marketplace. A parent company’s authorization doesn’t automatically cover the product you’ll use.

Mistake 4 — “Encrypted CUI can sit anywhere.”Per DoD’s CMMC FAQ, a non-FedRAMP-Moderate cloud can’t store encrypted CUI for contract performance unless the provider meets Moderate-equivalent requirements. Encryption protects the data; it doesn’t waive the cloud requirement.

Mistake 5 — “Our MSP has to be CMMC certified.”Not always. Under the final rule, an External Service Provider like an MSP isn’t required to hold its own CMMC certificate — though if it doesn’t, its in-scope assets fall into your assessment, which can complicate your timeline.

Mistake 6 — “FedRAMP equivalency is the same as FedRAMP authorization.”It isn’t. DoD materials are explicit that equivalency does not confer FedRAMP authorization — and equivalency puts the evidence-verification burden on you.

Mistake 7 — “NIST says 800-171 Rev. 2 is withdrawn, so this page is out of date.” Understandable, but no. NIST published SP 800-171 Rev. 3 in May 2024 and now marks Rev. 2 as superseded at the publication level — yet CMMC Level 2 still maps to Rev. 2under 32 CFR Part 170. Until DoD amends the rule, Rev. 2 is the controlling version for CMMC. Don’t let the NIST “withdrawn” banner fool you into building to the wrong revision.

What we verified for this guide

We treat primary-source citation as the job, not a footnote. Here’s exactly what we checked, and what we recommend you re-confirm because it’s moving.

Last verified: June 2026

What we intentionally did not state precisely, and which you should verify on your own publish date: a live FedRAMP Marketplace count or a current FedRAMP control count; product-specific FedRAMP status for named clouds like GCC High, GovCloud, and Azure Government (verify the exact offering on the Marketplace); and the final text of FedRAMP’s Consolidated Rules for 2026, expected by the end of June 2026.

What we do not claim:We are not affiliated with the Cyber AB, the Department of Defense, DCMA DIBCAC, NIST, GSA, or FedRAMP. We do not rank “best” providers, we do not guarantee certification outcomes, and we do not route you to a named provider from this page. This is educational research — confirm scope and applicability with a CMMC Registered Practitioner (RP/RPO) or a qualified federal-contracts attorney.

CMMC vs FedRAMP: FAQ

Your next step

You came here to find out whether CMMC, FedRAMP, or both apply to you. If you read one thing twice, make it this: CMMC follows your company; FedRAMP follows a cloud service; and when a DoD contractor puts CUI in the cloud, both are in play — your CMMC obligation doesn’t disappear, and your cloud has to be FedRAMP Moderate authorized or equivalent.Verify the exact cloud status on the Marketplace, document the controls you still own, and don’t let a vendor sell you one word (“certified,” “authorized,” “ready”) when you need another.

Need help deciding what type of CMMC provider you need?Tell us your level, scope, and timeline, and we’ll match you with source-checked CMMC provider options.