Most companies preparing for a CMMC assessment focus on their internal security controls but forget to ask a critical question: Is their managed service provider (MSP) compliant? An MSP plays a direct role in how sensitive data is handled, stored, and protected, which means its security posture affects your own compliance standing. Ignoring this factor can lead to unexpected failures when it’s time for an audit.
Why Your MSP’s Compliance Status Directly Impacts Your Own CMMC Certification
A company can spend months preparing for a CMMC assessment, ensuring its systems and processes align with CMMC compliance requirements. But if the MSP it relies on for IT services does not meet the same security standards, that effort can be wasted. Assessors evaluate not just internal controls but also how third parties with access to sensitive systems handle security.
If an MSP lacks compliance with CMMC level 2 requirements, it creates a weak link in your cybersecurity framework. This isn’t just about firewalls and encryption—it extends to access controls, incident response, and data protection measures. When auditors examine how a company secures controlled unclassified information (CUI), they expect every entity with access to follow the same strict guidelines. If an MSP falls short, the business that hired them bears the consequences.
Third-Party Security Gaps That Could Jeopardize Your Entire Assessment
Businesses often assume that their service providers have strong security controls in place, but that’s not always the case. An MSP may offer general cybersecurity protections, but those protections might not align with CMMC requirements. This is especially true for companies pursuing CMMC level 2 certification, where strict controls over CUI are required.
Even minor gaps in an MSP’s security framework can become major problems during an audit. If an MSP has improper access control measures, weak encryption, or lacks multi-factor authentication, it creates vulnerabilities that can be exploited. A single misalignment between an MSP’s security practices and CMMC compliance requirements can result in an assessment failure. Companies must actively verify that their MSP is operating at the same security level required for their own certification.
How to Verify If Your MSP Follows the Same Security Standards You Are Required to Meet
Trusting that an MSP meets CMMC compliance requirements is risky without verification. Companies should request clear documentation proving that their provider adheres to the same security standards required for certification. This isn’t just a formality—it’s a necessary step to ensure compliance before an audit.
Key steps to verify an MSP’s compliance include:
- Requesting formal documentation – An MSP should provide evidence of compliance with CMMC level 1 or CMMC level 2 requirements, depending on the company’s needs.
- Reviewing their security policies – Their cybersecurity framework should align with NIST 800-171 and include strong access controls, encryption, and risk management practices.
- Ensuring contractual obligations – Service agreements should explicitly state that the MSP follows all necessary CMMC assessment standards. Without a written commitment, verbal assurances mean little.
Without these measures, businesses risk failing their assessment due to third-party security weaknesses.
The Risk of Assuming Your MSP Handles Compliance Without Written Proof
Assumptions can be costly when preparing for a CMMC assessment. Many companies believe their MSP has already taken care of compliance, only to find out during an audit that key security controls are missing. This mistake often results from vague agreements where MSPs provide general IT services but lack a formal commitment to meeting CMMC requirements.
An MSP that does not explicitly state its compliance obligations in writing is a potential risk. Businesses should not wait until an audit to realize that their provider does not meet CMMC level 2 requirements. Instead, companies should demand clear proof of compliance, review their MSP’s security policies, and ensure those policies align with their own certification requirements. Without documented proof, there’s no guarantee that an MSP is maintaining the level of security necessary for compliance.
Data Handling Practices That Could Put Controlled Unclassified Information at Risk
Controlled unclassified information (CUI) is a major focus of CMMC level 2 assessments. If an MSP has access to CUI but lacks the proper security controls, it puts a company’s certification at risk. Even if a business follows every requirement internally, its compliance can be jeopardized if its MSP does not protect CUI correctly.
CUI must be encrypted in transit and at rest, stored only in authorized locations, and protected by strict access controls. If an MSP does not have proper data handling procedures in place, an auditor will flag this as a serious issue. To avoid compliance failures, companies must confirm that their provider follows strict CUI protection standards and does not store or process sensitive data in unsecured environments. A simple misconfiguration in an MSP’s systems can result in a compliance failure that affects the entire organization.
Incident Response and Monitoring Responsibilities That an MSP Must Meet
Cybersecurity incidents happen, and CMMC compliance requirements demand that organizations have a clear plan in place to detect, respond to, and recover from security breaches. If an MSP is responsible for monitoring a company’s network, it must meet the same strict incident response requirements outlined in CMMC level 2 standards.
An MSP’s role in incident response should be clearly defined in service agreements. This includes:
- 24/7 security monitoring – An MSP must continuously track potential threats and detect unauthorized activity.
- Rapid response protocols – A documented incident response plan should be in place, ensuring quick action if a breach occurs.
- Detailed reporting – MSPs must maintain records of security events, ensuring businesses have proper documentation for audits.
If an MSP fails to meet these responsibilities, the business that relies on them will struggle to pass its CMMC assessment. Compliance is not just about internal policies—it extends to every service provider that has access to sensitive systems and data. Businesses must confirm that their MSP is prepared to meet every requirement before their assessment begins.