Skip to content
ISI is officially CMMC Level 2 certified! Read our full press release here.
Talk to an Advisor
Talk to an Advisor

How to Choose a C3PAO

EXECUTIVE BRIEF

Finding a C3PAO is a critical step in your CMMC compliance journey. Here are a few characteristics defense contractors should look for: 

  • Experience working with similar businesses as yours
  • Availability that aligns with your compliance journey timeline
  • The ability to build rapport and communicate effectively with your assessment team

 

Dig deeper and continue learning below!

 

 

Achieving Cybersecurity Maturity Model Certification (CMMC) compliance is a high-stakes process for defense contractors, and choosing the right Certified Third-Party Assessor Organization (C3PAO) can make all the difference. Finding a C3PAO you can build rapport and communicate effectively can help streamline your compliance journey.

However, with limited authorized C3PAOs available, competition for their time is growing. Understanding what to look for in an assessor ensures your organization stays on track for compliance and remains eligible for DoD contracts. This guide will outline key factors to consider, warning signs to avoid, and the questions that will help you make the best choice.

 

 

What Is a C3PAO?

C3PAOs were established within the CMMC program to objectively evaluate contractor compliance, soon to be a requirement for any company seeking defense contracts. C3PAOs are responsible for assessing and certifying organizations seeking Level 2 certification (including, now, companies seeking Level 3 certification, which must demonstrate they’ve achieved Level 2 first before they move on to their government-led audit by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)). 

C3PAOs are authorized by The Cyber AB (formerly the CMMC Accreditation Body) to conduct official compliance audits to determine whether an organization meets the cybersecurity standards set by the DoD's CMMC framework. Some of their key responsibilities include:

  • Conducting formal CMMC level 2 assessments: Evaluating an organization’s cybersecurity posture to determine compliance with NIST SP 800-171 requirements.
  • Providing certification recommendations: Submitting assessment results to The Cyber AB, which oversees the final certification decision.
  • Ensuring impartiality and compliance: Maintaining independence by never providing both CMMC assessment and consulting services to the same contractor.

 

What to Consider When Choosing a C3PAO

Official Authorization & Expertise

Selecting an experienced C3PAO increases the likelihood of a smooth and efficient assessment process. Only C3PAOs listed on the Cyber AB marketplace are authorized to conduct CMMC Level 2 assessments, so verifying their official authorization is essential to ensuring their legitimacy and adherence to program requirements. 

Once you’ve determined that they’re authorized to conduct assessments, you should evaluate their experience and track record. A strong indicator of expertise is whether they’ve conducted Joint Surveillance Voluntary Assessments (JSVAs), the collaborative evaluation process through which defense contractors could voluntarily undergo an assessment by both a third-party assessor and the DIBCAC to identify and address cybersecurity gaps before CMMC 2.0 became mandatory. Experience with this process demonstrates their familiarity with CMMC compliance and NIST SP 800-171 requirements. 

Experience Working with Similar Businesses

When selecting a C3PAO, ask if they have experience working with a contractor similar in size and scope as your organization. System and network configuration vary greatly in the DIB. Finding a C3PAO who has assessed similar organizations demonstrates their ability to assess your organization and help streamline the audit process.

ISI Insight: If you're working with an External Service Provider or consultant to prepare for CMMC certification, ask if they recommend any trusted C3PAOs with a strong track record in the defense sector.

Availability & Scheduling

Demand for assessments is high, and availability and scheduling are crucial factors when selecting a C3PAO. Some C3PAOs have long wait times. This could delay your CMMC certification and impact your ability to secure government contracts. 

Before committing to a C3PAO, ask about their availability and whether they can accommodate your desired timeline. Pre-planning and choosing a C3PAO with the availability to meet your timeline will help prevent delays and keep your certification process on track.

Transparency & Communication

Transparency and communication are key when selecting a C3PAO. A reputable third-party assessor should clearly explain their assessment process, pricing, and expectations upfront, ensuring no surprises. Look for one that offers pre-assessment guidance, which can help you understand what to expect and how to prepare.

ISI Insight: Establishing strong communication and rapport with your C3PAO is essential, as a collaborative and responsive relationship can make the certification process much smoother.

Impartiality & Conflict of Interest

When selecting a C3PAO, impartiality matters. Your C3PAO must remain independent. They cannot provide consulting services to prepare you for certification and then also conduct your official audit. 

Be wary of Managed Service Providers (MSPs) that claim they can handle both preparation and assessment. This double duty creates a conflict of interest and violates CMMC guidelines.

Red Flags to Watch Out For

Be mindful of red flags indicating inexperience or unethical practices. Keep an eye out for:

  • Unrealistic guarantees: No C3PAO can promise certification, as assessments are based strictly on compliance with CMMC requirements.
  • A lack of references: This is another warning sign; reputable C3PAOs should be able to provide case studies, client testimonials, or past assessment experience to demonstrate their credibility.
  • Pushy sales tactics: If a C3PAO pressures you to commit quickly or makes vague claims about fast-tracking the process, it’s best to walk away. A trustworthy C3PAO will provide clear, transparent information and allow you the time needed to make an informed decision.

 

How to Prepare Before Engaging a C3PAO

Before scheduling your official CMMC assessment, take these steps to ensure readiness. Start by conducting a self-assessment using the NIST SP 800-171A Rev 2 scoring methodology to evaluate your current compliance status and identify any gaps in your compliance posture. You can also set yourself up with a Registered Provider Organization (RPO) or a trusted consultant who can help address deficiencies and implement necessary security controls before your formal audit. 

Additionally, ensure your System Security Plan (SSP) is complete and that all artifacts of evidence—such as policies, procedures, and technical documentation—are well-organized and readily accessible. This type of preparation streamlines the assessment process and increases your chances of achieving CMMC compliance on the first attempt.

FAQs about Choosing a C3PAO

What Does C3PAO Stand For?

C3PAO stands for Certified Third-Party Assessment Organization, an entity authorized by The Cyber AB to conduct CMMC assessments.

What Is the Cyber AB?

The Cyber AB is the official accreditation body of the CMMC ecosystem and the sole authorized non-governmental partner of DoD in implementing and overseeing the CMMC. 

What Are the 3 Levels of CMMC Compliance?

  • Level 1 | Foundational – For contractors only handling Federal Contract Information (FCI)  requiring adherence to 17 practices outlined in NIST 800-53
  • Level 2 | Advanced – For contractors handling Controlled Unclassified Information (CUI), requiring adherence to all applicable 110 NIST SP 800-171 practices and assessment obtained through a C3PAO
  • Level 3 | Expert – For contractors handling particularly sensitive CUI requiring an additional 24 controls selected from NIST SP 800-172 controls and assessment conducted by the DIBCAC

 

How Much Does a C3PAO Assessment Cost?

On average, assessments can range from $30,000 to $100,000+, depending on some of the following factors:

  • Company size
  • System complexity
  • Scope of the assessment
  • C3PAO pricing

 

How Long Does a C3PAO Assessment Take?

The length of a C3PAO assessment can vary based on the size and complexity of your organization, but the process typically unfolds in several stages

  • Preparation phase: Several months (depending on compliance gaps)
  • Formal assessment: Typically 3-5 days
  • Remediation (if needed): Up to 180 days
  • Final certification decision: This can take weeks to months after assessment completion.

 

What Are the Requirements for Becoming a C3PAO?

Becoming a C3PAO requires meeting strict criteria set by The Cyber AB. Organizations must first register with The Cyber AB and undergo a DIBCAC assessment to demonstrate compliance with NIST SP 800-171 security requirements.

Also, a C3PAO must employ Certified CMMC Assessors (CCAs) who have completed the necessary training and certification to conduct official CMMC assessments. Once approved, the C3PAO is listed on The Cyber AB marketplace, allowing them to perform CMMC Level 2 assessments for defense contractors.

Choosing a C3PAO: What's Next?

Choosing the right C3PAO is a critical step in achieving CMMC compliance. By selecting an experienced, transparent, and authorized assessment organization, you can streamline the certification process and protect your ability to compete for DoD contracts.

Need help finding a C3PAO or preparing for CMMC? Contact ISI for expert guidance on compliance strategies today, and we can help you ensure your organization is audit-ready.

Related Posts