CMMC and FedRAMP Moderate Equivalency for Cloud Services

What “FedRAMP Moderate Equivalency” Usually Means

In CMMC / DFARS cloud conversations, teams typically mean: the cloud service has an authorization baseline aligned to FedRAMP Moderate (or DoD Impact Level pathways that map to comparable control depth), so a portion of NIST SP 800-171 / CMMC Level 2 technical controls can be inherited from the provider’s authorization package.

Inheritance only covers controls the CSP actually performs. Customer configuration, admin identity, endpoint access to the tenant, and data classification remain on you.

What You Still Own

• Scoping which systems process, store, or transmit CUI
• Identity, MFA, privileged access, and account lifecycle for your tenant
• Endpoint and remote-access paths into the cloud enclave
• Logging review, alerting, and incident response (including DFARS 252.204-7012)
• Subcontractor / ESP flow-down for anyone who touches CUI in that environment

How Assessors Treat Cloud Inheritance

For Level 2 (110 NIST SP 800-171 Rev 2 requirements), expect assessors — whether self-assessment discipline or a future C3PAO designation — to ask for: CSP authorization artefacts you rely on, a responsibility matrix, configuration evidence for customer controls, and proof that CUI does not bleed into commercial tenants without compensating architecture.

See also MSPs / ESPs when a managed provider operates the tenant.

How CyberSilo Helps

• CSA tracks inherited vs customer-owned requirements
• ThreatHawk supports AU evidence for cloud and hybrid log sources
• Honest boundary coaching — we do not claim FedRAMP issues your CMMC status

Frequently Asked Questions

Does FedRAMP Moderate replace CMMC Level 2?

No. FedRAMP authorizes a cloud service for federal use. CMMC assesses the contractor organization against FAR basic safeguarding (L1) or NIST SP 800-171 Rev 2 (L2) for its FCI/CUI environment, including customer-owned controls.

Can I put CUI in commercial Microsoft 365?

Generally no for typical CUI handling paths used by DIB contractors — most programmes expect GCC High / Azure Government or another authorized path. Confirm with your contracts and CUI marking guidance.

Who documents inherited controls?

You do, in the SSP and responsibility matrix, citing the CSP authorization package and your residual configurations.

Related CMMC Resources

CMMC hub · CMMC vs FedRAMP · GCC High · Scoping · FedRAMP hub