CMMC vs. FedRAMP: Understanding the key differences and overlaps

For organizations working with the U.S. government, cybersecurity compliance is a top priority. Two of the most critical frameworks, the Cybersecurity Maturity Model Certification (CMMC) and the Federal Risk and Authorization Management Program (FedRAMP), are often referenced together, yet they address distinct security challenges.

FedRAMP provides the standardized process and requirements for authorizing cloud service offerings; the actual security authorizations are issued by the FedRAMP Joint Authorization Board (JAB) or individual federal agencies.

In this blog, we’ll break down the key differences and similarities between CMMC and FedRAMP, explain which applies to your role, and clarify how to approach compliance.

What is the difference between CMMC and FedRAMP?

CMMC and FedRAMP are both rigorous U.S. government cybersecurity programs, but they serve fundamentally different purposes, protect different assets, and have different authorizing bodies.

• FedRAMP is the government-wide program that standardizes the security assessment, authorization, and continuous monitoring for cloud products and services (like IaaS, PaaS, and SaaS). Its goal is to ensure a consistent security baseline for cloud offerings used across federal agencies. The program is governed by Office of Management and Budget (OMB) policy, which mandates that agencies may only use cloud services that have received a FedRAMP authorization. FedRAMP’s security requirements are based on controls from NIST SP 800-53.
• CMMC, mandated by the DoD, is a certification model for organizations (contractors and subcontractors) that handle Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). It verifies that an organization has implemented the required security practices to protect sensitive data, whether it's in the cloud, on-premises, or in a hybrid environment.

In short, FedRAMP is about authorizing a cloud service for government-wide use. CMMC is about certifying an organization’s cybersecurity posture to protect specific defense-related information.

At a glance: The differences between CMMC and FedRAMP

Which one should you choose?

The choice isn't between CMMC or FedRAMP; it depends entirely on your business model and the type of work you do for the government.

• If you are a cloud service provider (CSP) selling software, platform, or infrastructure services to any federal agency, you need FedRAMP authorization for your offering.
• If you are a DoD contractor or subcontractor handling FCI or CUI as part of a defense contract, you need CMMC certification at the required level. 
• If you are a DoD contractor using a cloud service (like AWS or Azure) to handle CUI, you need both. The cloud platform must be FedRAMP authorized, and your configuration, data, and management within that platform must meet CMMC requirements. You are responsible for the security of your tenant and data.

Examples for clarity:

• A SaaS company providing HR software to the Department of Energy needs FedRAMP authorization.
• A small business manufacturing a component for a DoD weapons system and handling technical drawings (CUI) needs CMMC Level 2 certification.
• A prime defense contractor using Microsoft 365 GCC High to collaborate on a classified project needs to ensure their tenant is configured to meet CMMC Level 2 controls within the FedRAMP-authorized GCC High environment.

What is CMMC?

CMMC is a cybersecurity certification program developed by the DoD to ensure that contractors and subcontractors in the DIB safeguard FCI and CUI according to required security standards. It builds on existing frameworks like NIST SP 800-171 by adding a mandatory verification and certification layer that confirms the required controls are properly implemented and maintained.

Any organization that handles FCI or CUI under a DoD contract must achieve the appropriate CMMC level. For Level 2 (CUI) on prioritized DoD acquisitions, this requires an independent assessment conducted by a Certified Third-Party Assessment Organization (C3PAO). For non-prioritized acquisitions, an annual self-assessment may be permitted.

The timeline for achieving certification varies significantly by level and readiness. For CMMC Level 2, organizations often require 6 to 12 months for remediation and assessment. For more complex environments or Level 3, the process can extend 18 months or more. Costs vary widely based on size, complexity, and starting point but can range from $50,000 to $250,000+, covering gap analysis, remediation, documentation, and the assessment fee.

Why is CMMC important?

CMMC plays a critical role in protecting the DoD supply chain by ensuring that every contractor handling sensitive information maintains a verified level of cybersecurity maturity. It is a direct response to sophisticated cyber threats targeting defense data. Achieving certification is now a mandatory condition for award on relevant DoD contracts, making it essential for business eligibility, revenue protection, and mitigating legal risk under the False Claims Act.

What are the three levels of CMMC?

CMMC 2.0 includes three maturity levels designed to match the type of data an organization manages.

Level 1 (Foundational): CMMC level 1 applies to contractors handling only FCI, covering 17 basic practices.

Level 2 (Advanced): CMMC level 2 applies to organizations handling CUI. It assesses against all 110 security requirements from NIST SP 800-171.

Level 3 (Expert): CMMC level 3 applies to organizations supporting high-priority defense programs, adding enhanced controls from NIST SP 800-172 on top of the Level 2 foundation.

Do we need to renew CMMC certification?

Yes. CMMC certification is not permanent. Under CMMC 2.0:

Level 1: Requires an annual self-assessment.

Level 2: Requires a triennial third-party reassessment (or annual self-assessment for non-prioritized acquisitions).

Level 3: Requires a triennial government-led reassessment.

Continuous monitoring and maintaining evidence are essential between audits to ensure readiness.

Can you automate the CMMC certification process?

While the official assessment cannot be automated, the compliance process can be dramatically accelerated. Automation platforms can map controls, continuously collect evidence from integrated systems, manage policies, and track remediation via Plans of Action and Milestones (POA&Ms). This reduces manual effort, eliminates pre-audit scrambling, and helps maintain a state of continuous audit readiness.

What is FedRAMP?

FedRAMP is the standardized security assessment and authorization program for cloud products and services used by the U.S. government. It provides a "do once, use many times" framework to ensure cloud services meet consistent security baselines.

 CSPs undergo a rigorous assessment conducted by an accredited Third-Party Assessment Organization (3PAO) against one of three NIST SP 800-53 baselines (Low, Moderate, High) to achieve an Authority to Operate (ATO). The program's requirements are periodically updated; the current FedRAMP Rev 5 standard introduced significant changes to these security baselines and controls.

Any CSP selling to a federal agency must achieve FedRAMP Authorization. The process is extensive, often taking 18-24 months for a Moderate baseline authorization and costing $1 million or more in direct assessment and remediation costs, not including internal resource investment.

What are the requirements of FedRAMP?

FedRAMP requirements are defined by NIST SP 800-53 security control baselines, tailored for cloud environments.

Low baseline: Approximately 156 controls for data with limited impact.

Moderate baseline: Approximately 321 controls for the majority of federal data, including CUI.

High baseline: Approximately 421 controls for data that would cause severe damage if compromised.

CSPs must document compliance in a System Security Plan (SSP) and undergo continuous monitoring.

Is FedRAMP compliance mandatory?

Yes, for CSPs. An OMB mandate requires federal agencies to only use cloud services that have a FedRAMP authorization. Without it, a CSP cannot officially sell its services to the government.

Can you automate FedRAMP compliance?

Yes, significantly. Given the scale of controls (hundreds), automation is critical for evidence collection, continuous monitoring, policy management, and audit trail maintenance. Automation platforms are essential for achieving and maintaining an ATO efficiently.

Are there any similarities between CMMC & FedRAMP?

Despite their different scopes, CMMC and FEDRAMP share important foundational principles:

1. Rooted in NIST standards: Both frameworks are built upon and directly reference NIST security controls (800-171 for CMMC, 800-53 for FedRAMP), ensuring a risk-based approach to security.
2. Require third-party assessment: Both mandate independent, third-party validation of security controls (C3PAOs for CMMC Level 2+ (prioritized), 3PAOs for FedRAMP).
3. Emphasize continuous monitoring: Certification/authorization is not a one-time event. Both require ongoing monitoring, assessment, and reporting to maintain compliance status.
4. Critical for government business: Achieving either is a non-negotiable requirement for conducting specific types of business with the U.S. government (CMMC for DoD contracts and FedRAMP for selling cloud services).

How Scrut simplifies navigating CMMC and FedRAMP 

Scrut provides a unified view to manage the complex, overlapping requirements of both CMMC and FEDRAMP. You can map a single control implementation to multiple frameworks (NIST 800-171, 800-53), automate evidence collection from your cloud environment and endpoints, and maintain a continuous audit trail for assessors. This eliminates duplicate work and provides a single source of truth, whether you are preparing for a CMMC audit or a FEDRAMP assessment.

FAQs

Can a FedRAMP-authorized cloud automatically make me CMMC compliant?

‍No. Using a FedRAMP-authorized cloud is a necessary starting point, but you are responsible for configuring the service and managing your data in compliance with CMMC requirements. The cloud provider's authorization does not transfer to your tenant's security posture.

If I am CMMC Level 2 certified, am I close to being FedRAMP Moderate?

Not directly. While both share security principles, FedRAMP Moderate is based on NIST SP 800-53, which has over 300 controls, many of which are more extensive or specific than those in NIST SP 800-171 (the basis for CMMC Level 2). Significant additional work is required to meet FedRAMP's distinct requirements for cloud service providers.

Does the DoD require FedRAMP?‍

Yes, for cloud services. The DoD requires that any cloud service it uses must be FedRAMP Authorized at the appropriate impact level. This is often specified in cloud-specific contracts and guides like the DoD Cloud Computing Security Requirements Guide (SRG).

As a contractor, am I responsible for my CSP’s FedRAMP authorization?

You are responsible for ensuring that any cloud service you use to handle government data has the appropriate authorization (e.g., FedRAMP Moderate or High). You must verify their authorization status, but you are not responsible for the CSP's audit process.

Can we pursue CMMC and FedRAMP simultaneously?

Yes, and an integrated GRC approach is the most efficient method. By using a platform that maps controls across both frameworks, you can implement and evidence security practices that satisfy requirements for both, reducing duplication of effort.