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What Does a C3PAO Do?
The Cybersecurity Maturity Model Certification (CMMC) program went into effect in December 2024, although it will not become mandated until the 48CFR is published (likely somewhere between July and October of 2025). Hopefully you have begun your CMMC compliance journey at this point. You might be wondering, however, about the role of the Certified Third-Party Assessment Organization (C3PAO) facet of the process. What exactly does a C3PAO do?
What is a C3PAO?
A C3PAO is an independent entity authorized by the Cyber AB (formerly the CMMC Accreditation Body) to conduct official CMMC assessments for organizations seeking certification, specifically for Level 2 compliance under CMMC 2.0.
Unless your contracting officer informs you that you need to comply with level 1 only, you cannot rely solely on self-assessments. If you handle, process, or transmit Controlled Unclassified Information, you will need a C3PAO to conduct your CMMC assessment.
A C3PAO’s Responsibilities Include:
- Planning and Executing CMMC Assessments
- A C3PAO organizes and leads the formal evaluation of your cybersecurity practices against the 110 requirements in NIST SP 800-171, which form the backbone of CMMC Level 2.Validating Implementation
- C3PAOs don’t just look at policy documents—they verify that security controls are not only documented but are operational, maintained, and effective. Expect interviews, system walkthroughs, and evidence requests.
- Ensuring Objectivity and Independence
- A C3PAO must remain independent. They cannot consult or prepare your environment for certification and then turn around and assess it. This separation of duties is foundational to maintaining trust in the CMMC ecosystem.
- Submitting Assessment Results to the DoD
- Upon completing your assessment, the C3PAO packages the results and submits them via the Cyber AB to the Department of Defense. If all criteria are met, your organization receives a certification valid for three years.
What C3PAOs Cannot Do
C3PAOs cannot offer consultative or remediation services to a company for which they will conduct an assessment. A company can choose a consultant to help prepare for the assessment, but a different company must serve as the C3PAO.
Why choose Smithers?
Smithers became an authorized C3PAO in early 2025. Offering more than 30 years of ISO and other management system auditing services, Smithers brings established credentials, experience, and expertise to every CMMC assessment. If you feel you are ready to talk about or schedule your CMMC assessment, contact us today.