The bottom line of CMMC 2.0

I had the opportunity to dive into the details of CMMC 1.0 and examine how 2.0 differs. And the bottom line is that CMMC v2.0 simply expounds on the role of the assessor, and does not redefine the 5 levels under v1.0.

Ok, ok - please hold your tomatoes!

Yes, CMMC 2.0 level 2 requires CMMC 1.0 level 3, but so does CMMC 2.0 level 3 - see what I mean?

I asked Google Bard to help me understand this, and it revealed that this becomes evident in the following changes:

  • The assessor's role has been expanded to include more responsibility for ensuring that organizations are compliant with CMMC.
  • The assessor must now have a higher level of experience and expertise in information security.
  • The assessor must now follow a more rigorous process when conducting an assessment.
These changes are designed to ensure that organizations are assessed more consistently and accurately under CMMC v2.0. 
They also reflect the growing importance of information security in the federal contracting environment.
Here are some of the specific changes to the assessor's role in CMMC v2.0:
  • The assessor must now have a minimum of five years of experience in information security.
  • The assessor must now be certified by a CMMC-accredited third-party organization.
  • The assessor must now follow a more rigorous process when conducting an assessment, including conducting interviews with key personnel, reviewing documentation, and testing controls.

These changes are designed to ensure that assessors have the knowledge and experience necessary to assess organizations for compliance with CMMC. They also reflect the growing importance of information security in the federal contracting environment.

Earlier, I mentioned level 3 of CMMC 2.0 - this simply means that the DoD assesses vs relying on a CMMC 3rd party assessor (C3PAO).

The changes to CMMC v2.0 are significant and will have a major impact on organizations that do business with the federal government. Organizations that are not already compliant with CMMC v1.0 should start planning now to achieve compliance with v2.0.

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