What You Need to Know About Third-Party Cybersecurity Assessments in California

The proposed updates to the CMMC framework include a third-party cybersecurity assessment conducted by an accredited assessor. 

Blog Post

9 minute read

May 15, 2024

Data privacy regulations are becoming widely adopted across industries and markets as we continue to see more data generated each year alongside the number of businesses handling consumer data also increasing rapidly. In California, this has driven the updates to the Cybersecurity Maturity Model Certification (CMMC) which now include mandatory third-party cybersecurity assessments.  

While the third-party assessments for CMMC compliance aren’t yet finalized as they were proposed in late 2023, the new requirements are set to finish rolling out by October 2026. With this in mind, it’s important for organizations to get ahead of these compliance updates and prepare for what’s to come.  

Join us below to learn everything you’ll need to know about the upcoming CMMC updates and required third-party cybersecurity assessments.

If you’re looking for ways to proactively bolster your security, check out Impact’s Cybersecurity Services for help building a powerful and comprehensive cybersecurity strategy!

What Is the Cybersecurity Maturity Model Certification (CMMC)?  

The CMMC framework is how the Department of Defense (DoD) ensures that companies operating within the Defense Industrial Base (DIB) prioritize cybersecurity.  

With evolving cyber threats posing significant risks to national security, the DoD identified the necessity for a standardized framework to bolster the cybersecurity posture of entities engaged in DoD contracts. CMMC emerged as the solution to fortify the defense supply chain against cyber threats and safeguard government information.

CMMC is structured to address longstanding challenges in cybersecurity practices across the DIB such as inconsistencies and vulnerabilities created by varied cybersecurity standards. The CMMC framework addresses this fragmentation by establishing unified cybersecurity requirements for all organizations participating in DoD contracts.  

By standardizing practices, CMMC aims to bolster the resilience of the defense supply chain and minimize the risk of cyber incidents jeopardizing national security.

The development of CMMC involved extensive collaboration among the DoD, industry stakeholders, and cybersecurity experts. Drawing from established frameworks like the NIST Special Publication 800-171, CMMC integrates best practices tailored to the defense sector's specific needs.  

This collaborative approach ensures that CMMC reflects current cybersecurity threats and mitigation strategies, providing a robust framework for organizations to protect sensitive information and comply with DoD cybersecurity requirements.

For organizations in California, CMMC presents both challenges and opportunities. Achieving compliance requires substantial investment in cybersecurity infrastructure and resources, however, compliance offers benefits such as enhanced resilience, eligibility for DoD contracts, and increased trust from stakeholders.  

Embracing the CMMC framework enables organizations in California to position themselves as trusted partners in the defense supply chain, contributing to national security and critical infrastructure resilience. 

The CMMC Tiers

The CMMC framework is structured into tiers, each representing a distinct level of cybersecurity maturity and corresponding security controls. These tiers serve as a roadmap for organizations to enhance their cybersecurity resilience and align with DoD cybersecurity requirements effectively.  

Tier 1 focuses on foundational cybersecurity measures, such as basic access control and password management, to establish a baseline level of security hygiene.  

The CCPA definition of Significant Risk

Tier 2 builds upon Tier 1 by incorporating more advanced security controls, particularly aimed at protecting Controlled Unclassified Information (CUI). Organizations operating at Tier 2 are required to implement all 110 security requirements specified in the NIST SP 800-171 framework, demonstrating a higher level of cybersecurity maturity and resilience.  

Finally, tier 3 is still in development, but is expected to address advanced persistent threats (APTs) targeting CUI and will require organizations to implement additional cybersecurity measures to mitigate sophisticated cyber threats effectively.

Tier 1: Foundational Cybersecurity Measures

Tier 1 serves as the foundational tier within the CMMC framework, focusing on establishing basic cybersecurity measures aimed at safeguarding Federal Contract Information (FCI). At this tier, organizations are required to implement a set of fundamental cybersecurity practices derived mainly from the Federal Acquisition Regulation (FAR) Clause 52.204-21.  

These practices lay the groundwork for ensuring the protection of sensitive information not intended for public release, providing a baseline level of cybersecurity hygiene. Tier 1 is designed to address basic cyber threats and vulnerabilities, setting the stage for more advanced cybersecurity practices in higher tiers.

Tier 2: Advanced Cybersecurity Practices

Tier 2 represents a significant advancement in cybersecurity maturity, with a primary focus on the protection of Controlled Unclassified Information (CUI).  

Aligned with the NIST SP 800-171 framework, Tier 2 mandates the implementation of all 110 security requirements specified in this standard. Additionally, organizations must establish and document mature processes to guide their cybersecurity efforts, aiming to achieve a state of "good cyber hygiene" and enhance the protection of sensitive information against cyber threats.  

Tier 2 builds upon the foundational cybersecurity practices of Tier 1, introducing more robust security controls and processes to mitigate advanced cyber threats and enhance organizational resilience.

Tier 3: Expert Cybersecurity Capabilities

Tier 3, addresses advanced persistent threats (APTs) targeting CUI. Building upon the foundational and advanced cybersecurity practices of Tiers 1 and 2, Tier 3 denotes the highest level of cybersecurity expertise, reserved for entities with high risk factors and capabilities critical to national security interests.  

In addition to bringing more robust cybersecurity measures to the table that address the most sophisticated cyber threats on the market, CMMC tier 3 compliance also requires regularly scheduled third-party cybersecurity assessments without exception.

CMMC tier 3 compliance is one of the most stringent set of compliance regulations an organization can aim for, going above and beyond the 110 cybersecurity controls defined by the NIST framework and required for tier 2 compliance.

The Third-Party Cybersecurity Assessment Requirement  

The requirement for third-party cybersecurity assessments conducted by Certified Third-Party Assessor Organizations (C3PAOs) lies at the core of achieving CMMC compliance moving forward. These assessments serve as independent validations, offering stakeholders assurance regarding an organization's adherence to CMMC standards.  

Through engagements with reputable C3PAOs, organizations not only undergo rigorous evaluations but also gain valuable insights into their cybersecurity strengths and weaknesses. These insights empower organizations to make informed decisions aimed at mitigating risks and enhancing their overall security posture, in turn, bolstering resilience against cyber incidents that do occur.

In addition to bolstering cybersecurity defenses, third-party cybersecurity assessments fulfill essential roles in regulatory compliance and due diligence.  

Regulatory bodies, clients, and other stakeholders increasingly demand evidence of robust cybersecurity practices. By undergoing third-party assessments, organizations demonstrate their commitment to compliance and diligence in protecting sensitive information.

Furthermore, third-party assessments provide an objective evaluation of an organization's cybersecurity posture, free from internal biases or conflicts of interest. This enhances the credibility and reliability of assessment results, enabling organizations to validate their cybersecurity claims transparently.   

Overall, the requirement for third-party cybersecurity assessments underpins the integrity and efficacy of the CMMC framework. By engaging with reputable C3PAOs and undergoing thorough assessments, organizations can not only achieve compliance but also enhance their cybersecurity resilience and demonstrate their commitment to protecting sensitive information.  

Wrapping Up on The CMMC Third-Party Assessment

Navigating the complexities of cybersecurity compliance in California demands a comprehensive and proactive approach that now accounts for third-party cybersecurity assessments.  

By understanding the nuances of the CMMC framework and engaging with reputable C3PAOs, organizations can effectively fortify their cybersecurity defenses, mitigate cyber risks, and maintain regulatory compliance in the expanding digital world.  

Furthermore, embracing a culture of continuous improvement and adaptation is essential for staying ahead of emerging compliance and regulation requirements.

Visit Impact’s Cybersecurity Services page for help building out a layered and comprehensive cybersecurity strategy that protects your network, your data, and most importantly, your people!


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