The Cybersecurity Maturity Model Certification (CMMC) provides the foundation for protecting sensitive government information across the Defense Industrial Base (DIB). At its core, CMMC integrates principles from established frameworks like NIST SP 800-171 and NIST SP 800-172, creating a unified model that defines how contractors must safeguard Controlled Unclassified Information (CUI) and Federal Contract Information (FCI).
Understanding how this framework is structured, its levels, domains, and practices, is crucial for any organization seeking compliance. For companies leveraging Microsoft 365 and Azure, this understanding translates into practical implementation:
- Mapping cybersecurity controls to cloud services.
- Automating evidence collection.
- Austaining readiness across dynamic digital environments.
CMMC Framework Overview
The CMMC framework is structured to measure an organization’s cybersecurity maturity. Rather than serving as a single checklist, it defines a layered model of capabilities that become more sophisticated as security requirements increase.
The framework is organized into three primary components:
- Maturity Levels – Define the level of advancement and reliability of an organization’s cybersecurity capabilities.
- Domains – Represent high-level areas of cybersecurity practice (e.g., Access Control, Incident Response, Risk Management).
- Practices and Processes – Detail the specific controls and procedural actions necessary to achieve compliance at each level.
Together, these components provide a roadmap for continuous improvement, moving from foundational cyber hygiene to advanced, proactive defense.
From Compliance to Capability Maturity
Unlike static compliance frameworks, CMMC measures capability maturity. This concept means that organizations are evaluated not only on the controls they have, but also on how consistently and effectively they are implemented.
At lower levels, the focus is on protecting Federal Contract Information (FCI) through basic safeguards. Higher levels introduce advanced risk management, incident response integration, and continuous monitoring.
This approach ensures that as threats evolve, organizations mature with them, embedding cybersecurity resilience into their culture and operations.
The Three CMMC Levels
The current CMMC 2.0 and the upcoming 3.0 models define three maturity levels rather than the original five. Each level corresponds to specific control requirements and assessment rigor:
| Level | Focus | Primary Standard | Assessment Type |
|---|---|---|---|
| Level 1: Foundational | Basic safeguarding of the Federal Contract Information (FCI) | FAR 52.204-21 | Annual self-assessment |
| Level 2: Advanced | Protection of Controlled Unclassified Information (CUI) | NIST SP 800-171 | Third-party C3PAO assessment |
| Level 3: Expert | Protection against advanced threats | NIST SP 800-172 | Government-led assessment |
This structure reflects a balance between accessibility and assurance. Small contractors handling only FCI can self-assess, while those working with CUI must undergo formal third-party or DoD assessments.
In cloud-based environments, these levels determine the extent of required technical configuration for Microsoft 365 GCC or GCC High, and Azure Government.
CMMC Domains Explained
The CMMC framework includes 14 cybersecurity domains, each representing a key area of control implementation. These domains are derived primarily from NIST SP 800-171 and align with specific CMMC practices.
The 14 domains are:
- Access Control (AC)
- Awareness and Training (AT)
- Audit and Accountability (AU)
- Configuration Management (CM)
- Identification and Authentication (IA)
- Incident Response (IR)
- Maintenance (MA)
- Media Protection (MP)
- Personnel Security (PS)
- Physical Protection (PE)
- Risk Management (RM)
- Security Assessment (CA)
- System and Communications Protection (SC)
- System and Information Integrity (SI)
Each domain contains objectives, practices, and assessment criteria that specify how to implement controls effectively.
For example, within the Access Control (AC) domain, requirements include enforcing least privilege, session locks, and controlling external connections—all of which can be managed through Microsoft Entra ID Conditional Access and Privileged Identity Management (PIM) in Entra ID and Azure.
Practices and Assessment Objectives
Each CMMC domain contains multiple practices, and each practice has detailed assessment objectives that define how compliance is demonstrated.
For example, the Audit and Accountability (AU) domain includes practices such as:
- Generating and protecting audit logs.
- Reviewing and analyzing logs for anomalies.
- Retaining audit records for a defined period.
In a Microsoft environment, this translates to enabling Microsoft Purview Audit, configuring Azure Monitor, and integrating with Microsoft Sentinel for correlation and long-term log storage.
Each assessment objective corresponds to a verifiable action or configuration, enabling evidence, such as reports, screenshots, or policies, to confirm compliance.
Mapping CMMC to NIST Frameworks
CMMC practices are mapped directly to NIST SP 800-171 and, at higher levels, NIST SP 800-172.
This mapping ensures consistency across federal cybersecurity expectations and eliminates redundancy for contractors already working toward NIST compliance.
| CMMC Element | NIST Reference | Microsoft Example |
|---|---|---|
| AC.L2-3.1.1 – Limit system access | NIST 3.1.1 | Conditional Access policy in Entra ID |
| AU.L2-3.3.2 – Review and analyze logs | NIST 3.3.2 | Azure Sentinel log analytics |
| SC.L2-3.13.8 – Encrypt CUI in transit | NIST 3.13.8 | TLS enforcement in Exchange and SharePoint Online |
For Microsoft 365 and Azure users, this mapping provides clear implementation guidance, ensuring each CMMC control is tied to a corresponding technical capability.
Processes and Documentation
In addition to technical practices, CMMC requires organizations to demonstrate documented and repeatable processes.
This includes policies, standard operating procedures (SOPs), and governance frameworks that support consistent control execution.
For example:
- An Incident Response Plan (IRP) outlines how to detect, contain, and recover from security incidents.
- A Configuration Management Policy defines how changes to systems are approved and tracked.
- A Security Assessment Policy governs periodic self-evaluations and corrective actions.
Microsoft tools such as Compliance Manager, Microsoft Purview, and Defender for Cloud can automate much of the evidence collection process and track implemented controls, owners, and status over time.
Assessment and Validation
CMMC assessments rely on objective evidence. Assessors will examine:
- Technical configurations (e.g., firewall settings, encryption status).
- Operational procedures (e.g., user provisioning workflows).
- Documentary evidence (e.g., system security plans, training records).
In Microsoft environments, evidence can often be generated directly from administrative portals:
- Defender for Cloud – configuration compliance reports.
- Purview Audit – user and admin activity logs.
- Azure AD Sign-In Logs – MFA and conditional access compliance.
This evidence-driven approach ensures transparency and reproducibility, forming the backbone of the CMMC assessment process.
Continuous Monitoring and Maturity Progression
One of the defining features of the CMMC framework is its emphasis on continuous monitoring and improvement.
Compliance is not a one-time certification; it’s an ongoing operational state.
Organizations are expected to:
- Continuously monitor control performance using tools such as Microsoft Sentinel and Defender for Cloud.
- Periodically review and update security policies.
- Track remediation efforts via Plans of Action and Milestones (POA&Ms).
- Ensure that training, awareness, and documentation evolve alongside technology.
This continuous improvement mindset reflects the maturity principle at the heart of CMMC—ensuring organizations remain secure as threats and technologies evolve.
CMMC and the Cloud Shared Responsibility Model
Microsoft’s cloud environments follow the shared responsibility model, which defines which security tasks are Microsoft’s responsibility and which remain the customer’s.
| Responsibility | Microsoft 365/Azure Handles | Customer Handles |
|---|---|---|
| Physical security | ✔️ Data center controls | ❌ End-user devices |
| Platform security | ✔️ Hypervisor, OS patching | ❌ Configuration hardening |
| Data protection | Shared (encryption managed by both) | ❌ Access control policies |
| Compliance reporting | ✔️ SOC, FedRAMP, DoD certifications | ❌ Customer SSP and evidence |
Understanding this division is essential when scoping CMMC controls. For example, encryption at rest is managed by Microsoft, but key management (Azure Key Vault policies) and access reviews remain the organization’s responsibility.
How Microsoft 365 and Azure Support the Framework
Microsoft’s government cloud offerings are purpose-built to help organizations align with CMMC and related standards.
- Microsoft 365 GCC and GCC High provide compliant collaboration environments for handling FCI and CUI.
- Azure Government enables infrastructure isolation and FedRAMP High controls that align with NIST SP 800-171 and 172.
- Compliance Manager directly maps CMMC practices to technical configurations.
- Microsoft Defender XDR Suite delivers advanced detection, incident response, and evidence reporting for CMMC Level 2 and Level 3 readiness.
By aligning security operations with these tools, organizations can implement CMMC controls with precision and auditable visibility.
Common Missteps in Understanding the Framework
Even experienced organizations struggle with a few recurring issues:
- Treating CMMC as a checklist instead of a maturity framework.
- Failing to align domains and practices to actual system boundaries.
- Over-scoping and including non-CUI systems unnecessarily.
- Relying solely on policy documentation without verifying technical enforcement.
- Not leveraging automation for continuous control monitoring.
Addressing these pitfalls requires not only understanding the structure but also operationalizing it through tools, workflows, and governance.
Conclusion
The structure of the CMMC framework is far more than a compliance model—it’s a blueprint for building resilient, data-driven, and secure defense operations. Understanding how levels, domains, and practices interconnect allows contractors to create an architecture that’s both compliant and adaptive.
When implemented within Microsoft 365 and Azure, CMMC’s structure becomes actionable: identity, access, logging, and encryption controls can be mapped, monitored, and continuously improved using native cloud tools.
By mastering the structure of the CMMC framework, organizations position themselves not only for certification, but for enduring cybersecurity excellence across their digital environment.