ISI Insights

Are There MSPs That Are CMMC Certified? Yes. Does That Mean You’re Compliant? No.

Written by ISI | Feb 27, 2026 9:52:04 PM

Executive Brief

Yes, there are Managed Service Providers (MSPs) that have achieved Cybersecurity Maturity Model Certification (CMMC).

No, that does not mean your company is automatically compliant by working with them.

This is one of the most common misconceptions we see in the Defense Industrial Base (DIB).

An MSP’s certification reflects their internal environment, not yours.

If your organization handles Controlled Unclassified Information (CUI), you are responsible for implementing and documenting all 110 National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 controls within your own environment.

CMMC does not “flow down” from your MSP. It applies to the Organization Seeking Assessment (OSA). That’s you.

It is also important to distinguish between contractual compliance under Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012 (which requires NIST SP 800-171 implementation and Supplier Performance Risk System (SPRS) reporting) and CMMC certification under Title 32 of the Code of Federal Regulations (CFR), Part 170. These are related but distinct regulatory mechanisms.

Dig deeper below to learn what MSP certification really means and where the line of responsibility sits.

What It Means for an MSP to Be CMMC Certified

When an MSP earns CMMC Level 2 certification through a Certified Third-Party Assessment Organization (C3PAO), it means:

    • Their internal systems meet required controls
    • Their policies and procedures align with NIST SP 800-171
    • They passed an independent assessment

That certification applies to:

    • The MSP’s corporate network
    • The MSP’s internal data handling
    • The MSP’s operational environment

It does not automatically apply to:

    • Your Microsoft 365 tenant
    • Your endpoints
    • Your network architecture
    • Your access control decisions
    • Your documentation

An MSP can be secure themselves. That does not mean they have fully implemented controls inside your environment.

Under CMMC scoping rules, many MSPs function as External Service Providers (ESPs). Even if an MSP is certified, the services they provide to you may still fall within your CMMC Assessment Scope depending on how your CUI Assets, Security Protection Assets, or Contractor Risk Managed Assets are defined.

Why Your Organization Still Owns Compliance

Under Title 32 of the Code of Federal Regulations (32 CFR) Part 170, CMMC certification is tied to your specific environment(s) that store, process, or generate CUI.

If you handle CUI, you must:

    • Maintain your own System Security Plan (SSP)
    • Track remediation through Plans of Action and Milestones (POA&Ms)
    • Generate and maintain assessment evidence
    • Submit and maintain an accurate SPRS score

SPRS houses your NIST 800-171 DoD assessment score. If a contract requires CMMC, certification is a separate validation requirement (and the CMMC status is recorded in SPRS as well)

An MSP that has achieved Level 2 certification may have practical experience with C3PAO assessments and evidence expectations. However, that experience does not alter your organization’s independent responsibility for scope definition, implementation, and certification outcome.

Your MSP cannot submit that score on your behalf, and they cannot pass that certification on to you.

Where the Confusion Happens

We often hear: “Our MSP is CMMC certified, so we’re covered.”

In certain hosted enclave architectures, storing CUI within a certified MSP environment can reduce your internal technical scope.

But scope is determined by how CUI is processed, stored, transmitted, and protected, not by the MSP’s certification status alone.

An MSP may:

    • Provide secure infrastructure
    • Deploy endpoint detection and response tools
    • Configure multifactor authentication
    • Monitor logs
    • Assist with documentation

But you must still ensure:

    • Controls are fully implemented in your scoped environment
    • Access is properly restricted
    • Evidence exists and is organized
    • Policies match reality
    • Your System Security Plan (SSP) reflects actual operations

Certification is about implementation and documentation. Not association.

CMMC assessments are based on formally defined asset categories, including:

    • CUI Assets
    • Security Protection Assets
    • Contractor Risk Managed Assets (CRMAs)
    • Specialized Assets
    • Out-of-Scope Assets

An MSP’s certification does not automatically remove assets from your scope. Assets are included or excluded based on how they interact with CUI and must be properly categorized and documented in accordance with CMMC scoping guidance.

Shared Responsibility in Cloud Environments

In Microsoft 365 and other cloud-based environments, CMMC operates under a shared responsibility model. An MSP may configure security tooling, but your organization remains responsible for:

  • Tenant-specific access control policies
  • Role-based privilege assignments
  • Conditional Access configuration
  • Audit log retention and review
  • Data loss prevention (DLP) policies
  • Evidence demonstrating control effectiveness

An MSP’s certification does not validate your tenant configuration, user management, or administrative controls.

What a Strong MSP Actually Provides

The right MSP can dramatically accelerate readiness.

Especially if they:

    • Understand CMMC scoping and segmentation
    • Configure tenants aligned with NIST SP 800-171
    • Support evidence collection
    • Align technical controls to compliance requirements

Provide a security stack that has been assessed and vetted. As we noted in our 2025 readiness outlook, CMMC 2.0 in 2025: What Defense Contractors Are Doing Now, demand for C3PAO assessments is increasing. Contractors are narrowing environments and formalizing remediation now and a knowledgeable MSP should be part of that strategy.

The Bottom Line

An MSP being CMMC certified is a positive signal as it shows they understand the framework and they passed their assessment.

It does not mean your organization has:

    • Implemented all 110 controls
    • Properly scoped your CUI environment
    • Generated required documentation
    • Closed high-weighted control gaps
    • Earned your own certification

CMMC is environment-specific. You cannot outsource accountability, but you can outsource expertise. And that’s where the distinction matters.

FAQs

If my MSP is CMMC Level 2 certified, does that reduce my assessment scope?

Not automatically. If your CUI is stored and processed within a logically separated MSP-hosted enclave that has achieved its own Level 2 certification, your internal technical footprint may be reduced. However, that MSP environment is still treated as an ESP and remains part of your CMMC Assessment Scope. The MSP’s certification does not remove the environment from scope; it allows the assessor to rely on the MSP’s validated controls as part of the documented shared responsibility model.

Can my MSP speak to the assessor on my behalf?

Yes, they can support technical explanations during an assessment. However, the Organization Seeking Assessment remains responsible for documentation accuracy and control ownership.

Should I only work with an MSP that is CMMC certified?

It is a strong indicator of maturity, but certification alone is not enough. You should evaluate whether the MSP understands scoping, documentation, POA&M management, and how to prepare you specifically for a third-party assessment. Finding Level 2 certified service providers who also have achieved Registered Provider Organization status is the surest way to confirm a company’s expertise in CMMC.

Does my MSP have to become CMMC certified?

No, but it should be concerning if your MSP is not seeking their own certification. If your MSP stores, processes, or transmits your CUI—or provides security protections for your CUI environment—they may also be subject to contractual DFARS flow down requirements and potentially CMMC requirements, depending on the structure of your agreements.

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