ISO 27001, SOC 2, and the US Department of War (DoW)’s Cybersecurity Maturity Model Certification (CMMC) program are all comprehensive, trusted frameworks that provide an independent evaluation and attestation of an organization’s cybersecurity and compliance posture. ISO 27001 and SOC 2 have both been in voluntary use for about two decades by thousands of companies. Many executives in the US defense industrial base (DIB) have a sense of the “lift” required to align with these standards, and many defense contractors already have an ISO 27001 certification or SOC 2 report.

But CMMC has a very different premise from its forerunners, being a mandated cybersecurity standard created specifically for DIB orgs that handle federal contract information (FCI) and controlled unclassified information (CUI) on non-government systems. Thousands of defense suppliers will soon need to pass an independent CMMC Level 2 compliance audit if they want to continue doing business with the US Department of War (DoW) or its prime contractors.

How will CMMC compare to ISO 27001 and SOC 2 in terms of cost, timetable, and effort level needed to achieve compliance? This article unpacks the most important realities and considerations to help DIB orgs prepare. 

Key takeaways

• Just as ISO 27001 is generally considered a more prescriptive and comprehensive cybersecurity attestation pathway than SOC 2, CMMC is widely viewed as significantly more demanding than ISO 27001. Besides mandating more controls, CMMC certification requires more documentation and more detailed evidence of compliance.
• Preparing for a CMMC Level 2 third-party assessment includes some additional concerns versus getting ready for an ISO 27001 or SOC 2 external audit. 
• SOC 2 or ISO 27001 experience is an excellent foundation and starting point for CMMC certification.

CMMC, ISO 27001, and SOC 2 broadly compared

CMMC, ISO 27001, and SOC 2 have much in common, but each has a specific scope and intention:

• ISO 27001 is a globally recognized, voluntary standard that any business can apply to its cybersecurity program. Its focus is on establishing an information security management system (ISMS) that can protect all types of sensitive data, from digital records to hardcopy documents. Key requirements include management oversight and risk management practices. An ISO 27001 certification requires an independent compliance audit and is good for three years.
• SOC 2 is a customizable set of criteria designed to assess and rate the effectiveness of an organization’s data processing systems regarding security, availability, and integrity, along with confidentiality and privacy. Like ISO 27001, SOC 2 is widely applicable to different types of companies. But a SOC 2 examination yields a detailed attestation report, not a certification. A SOC 2 report can cover either a point in time (SOC 2 Type 1) or a span of time (SOC 2 Type 2).
• CMMC is a DoW-mandated cybersecurity compliance program based on the NIST SP 800-171 Rev. 2 standard, which was specifically created to protect FCI and CUI where it resides on contractor systems. Defense suppliers that handle CUI must meet CMMC Level 2 requirements, including a third-party audit every three years with an annual self-assessment and compliance affirmation by a senior leader.

ISO 27001 is generally considered more rigorous than SOC 2 because it is more prescriptive and comprehensive, with a requirement to implement, document, and continuously improve a complete information security management system (ISMS) to achieve and maintain certification. The SOC 2 framework is seen as comparatively more flexible and customizable, and as a faster and less expensive route to achieving an independent cybersecurity attestation. 

CMMC is a larger, more prescriptive standard than either ISO 27001 or SOC 2. In particular, CMMC requires all covered orgs to implement the full set of controls defined for the contracted CMMC certification level (e.g., 110 controls at CMMC Level 2), with no exceptions or opt-outs for non-applicability. CMMC also includes a range of specific requirements for handling CUI that are not covered by ISO 27001 or SOC 2.

Why is CMMC compliance more difficult than ISO 27001 or SOC 2?

Many DIB companies underestimate the effort required to achieve CMMC compliance because they compare it to SOC 2 or ISO 27001, which they may have already attained. But CMMC is “on another level” of complexity across the board, from scoping the CUI environment to implementing the extensive controls to maintaining the audit and compliance documentation. 

Many firms will need to extend their current cybersecurity infrastructure to meet CMMC requirements. For example, this often includes moving their email environment to a “government cloud” to meet strict CUI protection and access restrictions. 

Commonly cited reasons why CMMC compliance is more demanding than ISO 27001 or SOC 2 include:

• • Mandatory compliance enforcement to participate in DoW contracts.
    Many prime contractors are requiring CMMC Level 2 compliance for subcontractors that handle CUI well ahead of the DoW phased rollout timeline to ensure competitiveness. 
  • More mandatory controls.
    Its greater scope and range of controls make CMMC compliance notably more difficult and complex to achieve and maintain. CMMC Level 2 requires implementing all 110 controls from NIST SP 800-171. In comparison, ISO 27001:2022 includes 93 controls, some of which an organization can designate as not applicable based on its risk assessment. A typical cybersecurity focused SOC 2 report encompasses approximately 64 criteria. 
  • CUI specific requirements.
    CMMC requirements around protecting CUI in defense environments are highly specific and demanding to implement relative to comparable ISO 27001 or SOC 2 data protection controls, which are more generic and flexible. For example, CMMC includes highly detailed technical requirements, such as robust encryption standards and exact vulnerability scanning processes. Few ISO 27001 or SOC 2 requirements are as technically prescriptive. 

• Much higher cost.
  Reflecting its greater scope, complexity, and prescriptiveness, the cost to attain CMMC Level 2 certification is significantly greater than gaining ISO 27001 certification or a SOC 2 report. While costs vary widely based on company size, current cybersecurity posture, and many other factors, the official DoW baseline estimates “average” CMMC Level 2 certification costs at about $100,000, with overall investments including audits often exceeding $200,000. Most estimates put total ISO 27001 or SOC 2 certification costs in the $15,000 to $60,000 range. Staffing costs are also higher for CMMC due to a need for more roles, more training/upskilling, and more specialized cybersecurity and compliance expertise. 

• Longer implementation times.
  Typical SOC 2 or ISO 27001 implementation timelines range from 3 to 12 months depending on a firm’s current cybersecurity posture, with 6 to 9 months being about average. Experience is showing that CMMC Level 2 implementation timelines are more commonly 12 to 18 months. 

• More demanding audit protocols.
  CMMC, SOC 2, and ISO 27001 all require third-party certification and recertification audits. But the DoW evidence requirements and oversight mechanisms for CMMC audits focus on demonstrating continuous compliance, making these audits much more time-consuming and rigorous to prepare for and undergo. ISO 27001 and SOC 2 evidence requirements are broader compared with CMMC’s highly prescriptive artifact requirements (configuration records, audit trail logs, proof of training) for each control, for instance. While SOC 2 and ISO 27001 audit timelines are generally one to two weeks, CMMC audits frequently last two to four weeks, entailing correspondingly greater cost and effort.

• Much greater documentation requirements.
  ISO 27001 and SOC 2 have significant documentation and policy requirements that run to hundreds of pages. With CMMC, the System Security Plan (SSP) alone is often 400-plus pages and includes several times more evidence artifacts along with detailed implementation specifications for each of the 110 controls at Level 2. 
• Potential audit time pressure/delays.
  The ISO 27001 and SOC 2 audit ecosystems have had years to evolve, with an ample choice of accredited audit partners available for businesses seeking assessments. CMMC Level 2 certification, by comparison, relies on DoW-authorized CMMC Third-Party Assessment Organizations (C3PAOs) accredited by the Cyber AB. There are currently only about 100 accredited C3PAOs, which are tasked with auditing an estimated 80,000 DIB contractors needing CMMC Level 2 certification. Given this supply/demand bottleneck, audit wait times are expected to reach 6 to 9 months or more. 

Can an ISO 27001 ISMS or SOC 2 controls support CMMC certification?

ISO 27001 or SOC 2 investments and experience can be an outstanding foundation for CMMC Level 2 certification efforts and ongoing compliance. There is significant overlap across these standards and control mappings are available (e.g., between ISO 27001 and NIST 800-171). 

Some of the potential benefits of leveraging SOC 2 or ISO 27001 for CMMC certification include:

• Reduced expense, duplication of effort, and time spent
• Reduced cybersecurity risk and faster time-to-value for CMMC
• Reduced overall cyber compliance risk and lower governance effort

While current controls and artifacts can support CMMC alignment, DIB orgs will need to modify, extend, and supplement some current controls and documentation to achieve CMMC Level 2 compliance. One of the biggest advantages of approaching CMMC from an existing cyber certification is the experience gained from having operationalized processes for control monitoring and continuous improvement.

What’s next?

Is your business ready for CMMC certification? 

CBIZ Pivot Point Security offers a full complement of CMMC advisory and consulting services. No matter where you are today, our comprehensive assessment, implementation, and remediation support will ensure you efficiently meet all necessary CMMC requirements.

Contact CBIZ Pivot Point Security today to schedule a consultation with a CMMC expert.