CMMC Compliance: Key Choices for Defense Contractors

A Comprehensive Guide for Defense Industry Contractors

Introduction

The Department of Defense (DoD) is rolling out significant changes to its cybersecurity requirements for contractors through the Cybersecurity Maturity Model Certification (CMMC) program. This framework is designed to enhance the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the defense supply chain. The CMMC requirements are being integrated into DoD contracts, with implementation beginning in late 2025 and full enforcement expected in subsequent years. Contractors and subcontractors must prepare to meet these standards to remain eligible for DoD business opportunities.

Perspective: Implications for Defense Contractors

For companies and individuals currently working with, or seeking to work with, the Department of Defense, CMMC brings new compliance obligations. The framework establishes multiple levels of cybersecurity maturity, with most contractors targeting Level 2 (Advanced) for contracts involving CUI. The phased rollout means prime contractors are already seeing CMMC requirements in solicitations, and subcontractors are expected to comply as requirements flow down contractually.

This article examines compliance options, the shared responsibility model, platform comparisons, audit readiness, and how Jadex Strategic Group’s Praesidium offering distinguishes itself. The goal is to equip compliance officers and decision makers with accurate, actionable information for navigating the evolving CMMC landscape.

Initial Steps: Assessing Organizational Structure and Compliance Needs

The first step for compliance leaders—such as Chief Technology Officers, Chief Compliance Officers, or Chief Information Security Officers—is to assess the organization’s current IT and cybersecurity posture. Key considerations include:

- Whether IT and cybersecurity functions are managed internally, outsourced to a Managed Service Provider (MSP), or handled by a hybrid team.
- The presence (or absence) of dedicated cybersecurity personnel.
- Existing compliance with frameworks such as NIST SP 800-171 (which underpins CMMC Level 2 requirements), DFARS 252.204-7012, and other applicable regulations.

A thorough gap assessment against CMMC Level 2 practices and processes is recommended to identify deficiencies and plan remediation.

Responsibility: Defining Internal vs. External Roles in IT and Cybersecurity

It is a common misconception that outsourcing IT or cybersecurity absolves an organization of compliance responsibility. Under CMMC and related DoD regulations, the contractor organization remains accountable for compliance—even when leveraging MSPs or cloud service providers. Regulatory authorities expect clear governance, with contractors responsible for policies, training, documentation, and evidence of compliance. While certain operational tasks can be delegated, ultimate responsibility cannot be transferred.

Organizations must document roles and responsibilities, ensure appropriate contractual agreements with third parties, and maintain oversight of their security posture. This clarity is essential for passing CMMC assessments.

Compliance Options: DIY, SaaS, IaaS/PaaS, Open-Source, and Cloud Providers

Organizations typically choose among several approaches to achieve CMMC compliance:

- Do-It-Yourself (DIY): Building and managing compliant environments using open-source or commercial technologies, often requiring significant internal expertise.
- Software as a Service (SaaS): Platforms like Microsoft 365 GCC High offer productivity tools and business applications that support CMMC and other federal compliance needs. Its integrated services, such as email, collaboration, document management, and security, help organizations meet regulatory standards like CMMC, NIST SP 800-171, and DFARS while maintaining operational efficiency.
- Infrastructure/Platform as a Service (IaaS/PaaS): Utilizing cloud providers such as AWS GovCloud or Google Cloud Assured Workloads, where compliance responsibilities are shared but require substantial customer management and configuration.
- Managed Service Providers (MSPs/MSSPs): Engaging third-party specialists to deploy and manage compliant environments, which can accelerate timelines but still requires organizational governance.

Each approach offers trade-offs in terms of cost, complexity, and control.

Framework Comparison: FedRAMP, DFARS, ITAR/EAR, DoD SRG, CMMC ML2, NIST SP 800-171 Support

When evaluating compliance solutions, ensure they support all relevant frameworks:

- FedRAMP High: Required for cloud services handling federal data; both Microsoft GCC High and AWS GovCloud are FedRAMP High authorized.
- DFARS 252.204-7012: Mandates implementation of NIST SP 800-171 controls for DoD contractors handling CUI.
- ITAR/EAR: Regulate export of defense-related data; solutions must restrict access to U.S. persons and meet data residency requirements.
- DoD SRG: Sets DoD-specific cloud security requirements.
- CMMC Level 2 (ML2): Encompasses 110 NIST SP 800-171 practices and requires third-party assessment for prioritized contracts.
- NIST SP 800-171: Baseline for protecting CUI in non-federal systems.

Note: As of late 2025, Google Cloud’s Assured Workloads does not fully support ITAR/EAR. Organizations with such requirements should confirm provider capabilities and contract terms.

Data Residency: U.S. Personnel and Regulatory Requirements

To comply with ITAR, EAR, and some CMMC requirements, solutions must ensure data residency within the United States and restrict administrative access to screened U.S. persons. Microsoft GCC High, AWS GovCloud, and compliant MSPs offer these controls. Open-source solutions and some cloud offerings may need additional configuration to meet these standards.

Deployment Models: SaaS vs. IaaS/PaaS vs. Open-Source

Deployment models influence compliance management:

- SaaS (e.g., Microsoft GCC High): The provider (Microsoft) manages most infrastructure and platform controls, simplifying customer responsibilities.
- IaaS/PaaS (e.g., AWS GovCloud, Google Assured Workloads): The customer is responsible for building, configuring, and documenting the environment to meet CMMC and related requirements.
- Open-Source/On-Premises: The organization must handle all aspects of security, compliance, and evidence management, which is resource-intensive.

A shared responsibility model applies in all cases, with the customer always accountable for proper use, data classification, access management, and demonstrating compliance.

Compliance Profiles: Ease, Time, and Cost Considerations

Compliance implementation varies by platform:

- Microsoft GCC High: Moderate implementation effort; built-in compliance tools like Microsoft Purview streamline evidence collection. Typical time to compliance is 6–12 months, with medium licensing and service costs.
- AWS GovCloud/Google Assured Workloads: Higher customer effort for architecture and documentation; time to compliance is often 12–18 months and costs are higher due to need for specialized expertise and consulting.
- Open-Source/On-Premises: Requires strong internal security and compliance teams; time to compliance is at least 12 months, with labor representing the primary expense.
- MSP/MSSP Managed Deployments: Can accelerate timelines (9–15 months), but still require organizational governance and incur ongoing service fees.

Organizations should budget for initial setup, ongoing maintenance, and periodic assessments.

Audit Readiness: Support Across Different Solutions

Audit readiness is critical for CMMC. Microsoft GCC High offers compliance management tools but places responsibility for evidence gathering and process documentation on the customer. AWS and Google provide security controls but less built-in audit support. Open-source environments offer minimal native guidance, relying on community or external consultants. MSPs may provide templates and readiness support, but customers must remain actively involved.

For CMMC Level 2, third-party assessments (conducted by CMMC Third-Party Assessment Organizations, or C3PAOs) are required for prioritized contracts. For other contracts, self-assessment and annual affirmation may suffice, but organizations should prepare for rigorous evidence collection and documentation.

Solution Fit: Matching Options to Organizational Needs

Selecting a compliance solution depends on the organization’s size, internal resources, contract requirements, and risk tolerance:

- Microsoft GCC High: Best suited for defense contractors with ITAR/EAR requirements and those seeking a streamlined path to CMMC Level 2 compliance.
- AWS GovCloud/Google Assured Workloads: Fit for larger organizations with robust internal cloud and security expertise.
- Open-Source/On-Premises: Appropriate for organizations with advanced internal teams and a preference for maximum control or avoiding vendor lock-in.
- MSP/MSSP Managed Solutions: Ideal for organizations seeking to outsource operations but willing to maintain governance and accountability.

Jadex Strategic Group’s Praesidium Offering and Differentiators

Jadex Strategic Group’s Praesidium solution specializes in delivering turnkey, cloud-native enclaves based on Microsoft GCC High, staffed exclusively by U.S. citizens to meet strict data residency requirements. Praesidium is configured to meet CMMC Level 2, NIST SP 800-171, and related frameworks, and offers:

- Accelerated deployment (operational in as little as 13 weeks for some organizations, depending on scope and readiness).
- Comprehensive training, documentation, and audit preparation resources.
- Predictable, transparent cost structure for budgeting.
- Extensive onboarding and hands-on guidance from CMMC and Microsoft compliance experts.

By focusing on both technical controls and organizational processes, Praesidium helps clients bridge gaps between technology, policy, and compliance, positioning them for success in CMMC assessments and federal contracting.

MSPs/MSSPs deploying GCC High typically offer managed or shared tenancy models. While they can reduce operational burdens and accelerate compliance timelines (9–15 months on average), ongoing costs may be higher and audit support can vary. Customers remain responsible for overall governance, policies, and demonstrating compliance to assessors.

Conclusion: Decision Factors and Next Steps

Choosing the right CMMC compliance solution requires a careful assessment of organizational needs, technical capabilities, contract requirements, and risk appetite. All paths demand strong internal knowledge, continuous oversight, and a commitment to maintaining compliance as requirements evolve. Jadex Strategic Group offers tailored solutions and expert guidance to help clients achieve, demonstrate, and sustain CMMC compliance efficiently. For more information or to explore partnership opportunities, contact Jadex Strategic Group.