What is a C3PAO?

The Cybersecurity Maturity Model Certification (CMMC) was established as a standard set of federal cybersecurity practices to ensure that organizations in the Defense Industrial Base (DIB) are able to properly secure sensitive data such as CUI, CTI, FCI,   and more. DIB contractors who come in contact with these data types in their information systems will eventually encounter the DFARS 7021 clause in their contracts, requiring them to attain a CMMC certification. 

CMMC requirements became enforceable in 2025 at the discretion of contracting officers. By the end of the phased rollout in 2028, all DIB contractors will need some level of CMMC to take contracts with the DoW. Once you determine the appropriate certification level for your organization and have implemented the relevant requirements, a C3PAO assesses your organization and determines if your organization has earned certification. 

What is a C3PAO? 

A CMMC Third Party Assessor Organization, or C3PAO, is an organization authorized by the Cyber-AB to conduct and deliver CMMC assessments after entering a contract with an Organization Seeking Compliance (OSCs). 

 The Cyber-AB has defined two key roles for organizations that help OSCs get certified: Registered Provider Organization (RPOs), who advise, and C3PAOs, who assess. To help you in the process of gaining CMMC compliance, you'll likely need help from, both, a C3PAO and an RPO.  

Cybersecurity practitioners and technical advisors (like Summit 7), known as RPOs, assist organizations in the pre-assessment process by providing CMMC guidance and support to OSCs. Typically, this can include pre-assessment, information system configuration, and updated or newly authored documentation and policies.  

Though a C3PAO can also be an RPO, the C3PAO cannot provide RPO-related services to an OSC they are assessing to avoid obvious conflicts of interest.  

How to Become a C3PAO 

After signing initial paperwork and paying all fees, a C3PAO is on its way to officially provide assessments to contractors seeking certification. The full process to become a C3PAO also requires the following: 

• The organization must be 100% US-citizen owned or complete a Foreign Ownership Control, or Interest (FOCI) background investigation if the company is public, an ESOP, or a global partnership 

• A successful completion of an DIBCAC audit for at least CMMC Level 2 compliance 

• Subject to an Organizational Background Check by the Cyber-AB via Dun & Bradstreet and have a DUNS number 

• Be registered in the Cyber-AB Marketplace 

• Possess an ISO 17020 certification 

In addition, the organization must carry a general liability policy with the Cyber-AB named among the insured, an errors and omissions policy, and a cybersecurity breach policy. The organization must also maintain an association with at least one RP, CCP, PA or CCA. Lastly, the organization also pays an annual fee of $3,000 USD to maintain its certification. 

Note: If a C3PAO uses an external Cloud Service Provider (CSP) to access, store, or process any CUI data, they must ensure that the CSP meets FEDRAMP Moderate standards, or that any gaps are addressed. If the CSP does not meet those standards it is the responsibility of the C3PAO to independently assess the CSP and provide that assessment to the Defense Contract Management Agency (DCMA) as part of their CMMC Level 2 assessment. 

How to Select a C3PAO For a CMMC Assessment 

The first way to vet a C3PAO is checking if the organization is listed in the cyberab.org directory; it is also useful if the organization is showcasing their AB Accreditation logo on materials, or their website. The ideal C3PAO would also have an established background of NIST 800-171, DFARS 7012, and other relevant federal cybersecurity mandates. 

Beyond these more obvious considerations, OSCs should ask: 

• What is the C3PAO's backlog and projected assessment schedule? 

• • If you need a certification before they can perform an assessment, then you will need to look elsewhere. 

• How many assessments have they completed? 

• • A more experienced C3PAO might be able to conduct a thorough assessment faster or with a smoother workflow, getting your organization certified more quickly.  

• How many organizations have they worked with in your specific industry or situation (manufacturing, biotech, foreign parent company, etc)? 

• • The additional experience can help them navigate your organization’s nuances. For example, companies that are completely on-premises or have solely cloud infrastructure may prefer a C3PAO with experience assessing similar OSCs. 

• How much do they charge for the assessment? 

• • Assuming a forty-hour, five day onsite assessment, estimates could range between $20,000 - $80,000 USD, the pricing variability is primarily due to location and expertise. Significantly higher or lower estimates may warrant additional scrutiny. 

In the process of searching for a C3PAO, be aware that some fraudulent organizations offered assessments well before the certification process had even been fully established. These fraudulent organizations often offer better-than-average pricing or promise timelines that are not realistic. 

The Cyber-AB’s standardized accreditation process for this role should help more organizations in the DIB progress in their journey toward CMMC compliance, ultimately strengthening the security that protects our nation and enables each organization in the DIB to reliably support the DoW. 

Guidance from C3PAOs

To learn more about C3PAOs, RPOs, and becoming CMMC compliant, reach out to experts at Summit 7.