04/22/2026
⁉️ Does your MSP need its own CMMC assessment to handle your CUI?
If you are an Organization Seeking Certification (OSC) storing Controlled Unclassified Information (CUI) in a non-cloud system provided by a Managed Service Provider (MSP), you need to know where the compliance burden falls.
⁉️ Does the MSP require its own CMMC assessment?
The short answer: 🚫 No. The MSP is not strictly required to hold its own CMMC certification.
➡️ However, the long answer requires a closer look at shared risk:
🔹 Simplifying the Process: While not required, an MSP should elect to perform their own self-assessment or undergo certification. Doing so drastically simplifies the assessment process for the OSC.
🔹 Matching Levels: If they are assessed, the MSP’s assessment level must be the same (or higher) than the level specified in your DoD contract, covering all in-scope assets.
🔹 The Shared Responsibility Matrix (SRM): This is the most critical factor. Even without a formal assessment of their own, if the MSP shares or holds responsibility for specific security controls under the SRM, they must meet CMMC requirements for those specific controls and objectives.
The Bottom Line: Your MSP might not need the official certification stamp on their own wall, but their cybersecurity posture and practices will directly dictate whether or not you pass your assessment.
Make sure your IT partners understand their end of the Shared Responsibility Matrix!