What Is a C3PAO and What Role Do They Play in CMMC?
A CMMC Third Party Assessment Organization (C3PAO) is an independent assessor authorized to evaluate contractor compliance with CMMC requirements. For many CMMC Level 2 contracts, a C3PAO is the gatekeeper to eligibility.
What Does a C3PAO Do?
C3PAOs are responsible for:
Conducting CMMC Level 2 third-party assessments
Evaluating implementation of NIST SP 800-171 controls
Reviewing evidence, documentation, and operational practices
Issuing assessment reports that determine certification status
C3PAOs do not provide remediation or consulting during an assessment. Their role is validation, not preparation.
When Is a C3PAO Required?
A C3PAO is required when a DoD contract designates Level 2 with third-party assessment. This typically applies to higher-risk contracts involving Controlled Unclassified Information (CUI). Contractors do not choose whether a C3PAO is needed. The requirement is set by the solicitation.
The C3PAO Assessment Process
A typical Level 2 assessment follows four stages:
Preparation – Scope confirmation, evidence collection, and readiness review
Assessment Execution – Control testing using the NIST SP 800-171A methodology
Findings – Identification of deficiencies and limited POA&M eligibility
Certification Decision – Results submitted to DoD systems for validation
Delays often occur when documentation or evidence is incomplete.
Why C3PAOs Matter
If a contract requires a C3PAO assessment and certification is not complete, the contractor is ineligible to bid or be awarded. There is no provisional access and no extension tied to assessment scheduling.
As CMMC adoption expands, C3PAO availability becomes a competitive factor.
What Contractors Should Do Now
Identify whether your contracts are likely to require third-party assessment, complete a NIST SP 800-171 gap analysis, and plan assessment timelines early. Waiting until a solicitation is released often leaves no room to recover.
C3PAOs do not slow CMMC. They enforce it.