A Side-by-Side Comparison Of CMMC 2.0, SOC 2, and ISO 27001
If you’re working with the Department of Defense (DoD), you’re likely navigating the requirements of the Cybersecurity Maturity Model Certification (CMMC). But, if you’re also doing business with companies outside the federal sector, there’s a good chance you’re dealing with additional standards like SOC 2 or ISO 27001, as commercial clients are increasingly prioritizing strong data security.
This often leaves IT, security, and compliance professionals wondering: If I’m already compliant with SOC 2 or ISO 27001, how close am I to meeting CMMC 2.0 requirements? Or If I’m focused on CMMC, what will it take to satisfy SOC 2 or ISO 27001 compliance as well?
Each of these frameworks has unique goals and criteria, especially when it comes to CMMC’s specific focus on protecting federal data. The good news is, there is a good deal of overlap among these security standards — and mapping controls across frameworks not only simplifies the compliance process but also strengthens your organization’s overall security posture.
Below, we’ll break down the differences and overlaps between CMMC 2.0, SOC 2, and ISO 27001 so you can see exactly what’s involved in aligning your controls across these standards.
What is the Cybersecurity Maturity Model Certification (CMMC)?
CMMC 2.0 is a cybersecurity standard created by the DoD to protect sensitive information within the defense supply chain, especially Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). Compliance is required for DoD contractors and subcontractors that work with the DoD and/or suppliers and service providers that might handle CUI/FCI as part of their work with federal agencies.
CMMC 2.0 compliance is broken down into three levels, depending on the type of information the organization handles.
- Level 1: Foundational ensures that companies implement basic cybersecurity practices to protect FCI.
- Level 2: Advanced aligns with NIST SP 800-171 Rev 2 and is designed for organizations handling CUI.
- Level 3: Expert incorporates additional NIST SP 800-172 controls to protect against Advanced Persistent Threats (APTs). APTs are highly sophisticated and targeted cyberattacks designed to infiltrate a network, remain undetected for extended periods, and systematically extract valuable data.
Recommended reading
The CMMC Compliance Hub
Overview of CMMC controls
CMMC 2.0 is among the most stringent security frameworks. Its controls are grouped into 14 domains that cover the critical areas of cybersecurity, giving organizations a structured way to safeguard sensitive information. These controls are primarily based on NIST SP 800-171, with Level 3 incorporating additional controls from NIST SP 800-172, and they’re designed to ensure that companies meet the DoD's security expectations for safeguarding sensitive data.
1. Access Control (AC): Controls who has access to information and systems, ensuring that only authorized users can view or modify sensitive data. It includes controls for user authentication, managing privileges, and securing remote access.
2. Awareness and Training (AT): Ensures employees understand cybersecurity policies, risks, and their responsibilities. This includes regular security awareness training and testing employees on their knowledge of security best practices.
3. Audit and Accountability (AU): Focuses on tracking and recording user activity within systems to detect and investigate security incidents. This includes logging and monitoring, as well as holding users accountable for their actions.
4. Configuration Management (CM): Involves setting up and maintaining systems securely. This includes defining secure configurations, managing software updates, and preventing unauthorized system changes.
5. Identification and Authentication (IA): Ensures that users and devices are properly identified before gaining access. Controls in this area often include multi-factor authentication and requirements for strong passwords.
6. Incident Response (IR): Outlines procedures for detecting, reporting, and responding to security incidents. This includes having a clear incident response plan and conducting periodic incident response training and testing.
7. Maintenance (MA): Ensures that system maintenance is conducted securely. This involves scheduling and monitoring maintenance activities and ensuring that repairs or updates do not compromise security.
8. Media Protection (MP): Covers controls for managing physical and digital media (like USB drives and hard drives) to prevent unauthorized access, use, or data leakage. It also includes requirements for securely disposing of media containing sensitive information.
9. Personnel Security (PS): Ensures that employees with access to sensitive data are trustworthy. This includes screening new hires and having clear policies for handling personnel departures or role changes.
10. Physical Protection (PE): Involves safeguarding physical access to systems and facilities. Controls here focus on securing physical locations, restricting access to sensitive areas, and monitoring physical security.
11. Risk Assessment (RA): Focuses on identifying, analyzing, and mitigating risks to an organization’s information systems. This includes conducting regular risk assessments and addressing identified vulnerabilities.
12. Security Assessment (CA): Involves evaluating the effectiveness of security controls. This includes performing self-assessments, audits, and any third-party assessments that might be required for CMMC certification.
13. System and Communications Protection (SC): Ensures that data is protected as it moves across networks. This includes encrypting sensitive information during transmission and controlling how systems interact with one another.
14. System and Information Integrity (SI): Focuses on protecting the accuracy and reliability of information and systems. Controls here include detecting and mitigating malware, handling system vulnerabilities, and monitoring for unauthorized changes.
Recommended reading
CMMC 2.0 Controls and How to Implement Them In Your Organization
Deep dive: CMMC 2.0 and SOC 2
SOC 2 (System and Organization Controls 2) is a widely recognized security framework that evaluates a company’s internal controls related to data security, privacy, and availability. Developed by the American Institute of Certified Public Accountants (AICPA), SOC 2 specifically focuses on protecting sensitive company and customer data.
Because both frameworks focus on safeguarding sensitive data, they have many similar requirements in areas like access control (restricting who can access information), incident response (responding to security breaches), and risk management (identifying and addressing vulnerabilities). Both frameworks also expect organizations to maintain detailed documentation of their processes, policies, and controls, and this documentation serves as evidence during assessments and audits.
What is the difference between SOC 2 Type 2 and CMMC?
CMMC 2.0 and SOC 2 both focus on protecting sensitive information, but they have different purposes and applications. CMMC is mandatory for organizations that handle FCI and/or CUI and is structured around protecting these specific types of federal data. SOC 2 compliance is optional but common for cloud service providers and SaaS businesses that need to demonstrate strong data protection standards to customers and partners.
While CMMC 2.0 is structured into three levels of compliance, SOC 2 is built on the five Trust Services Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy. While the Security criteria is required for all SOC 2 reports, companies can choose which of the other criteria to include, offering a level of flexibility that CMMC 2.0 does not provide. SOC 2 also offers two report types:
- Type 1 are point-in-time reports that assess whether the organization’s security controls are properly designed.
- Type 2 evaluates the operating effectiveness of those controls over a longer period of time, typically 3-12 months, making it more rigorous.
The assessment process is also different for CMMC than SOC 2. For CMMC, companies either self-attest for Level 1, complete an external audit by a C3PAO for Level 2, or undergo a government-led assessment for Level 3 to achieve certification.
SOC 2 audits must be conducted by a certified public accounting (CPA) firm. The report isn’t a formal certification like CMMC but rather an attestation report that verifies whether a company’s controls meet their chosen Trust Services Criteria. So SOC 2 doesn’t offer certification in the same way CMMC and ISO 27001 do — it’s more about having a verified third-party report to show clients and partners.
| CMMC 2.0 | SOC 2 | ISO 27001 | |
| Purpose | Protecting CUI and FCI within the DoD supply chain | Attesting to an organization’s security controls for protecting sensitive data | Establishing and maintaining an Information Security Management System (ISMS) to protect sensitive data |
| Structure | Three levels of compliance, based on the type of data handled | Five Trust Services Criteria: Security is required but the others are optional, and 2 different types of reports | Organized into clauses, with 93 possible controls in Annex A to satisfy clause requirements |
| Applicable to | Required for organizations that handle CUI and/or FCI within the Defense Industrial Base | Optional, but prioritized by SaaS companies that need to prove a strong security posture to remain competitive | Optional, but prioritized by SaaS companies that need to prove strong security and risk management practices to remain competitive |
| Assessment | Level 1 involves an annual self-assessment; Level 2 requires triennial assessment by C3PAO, Level 3 requires triennial government-led assessmen | Annual audit conducted by accredited CPA firm | Initial certification audit, followed by annual surveillance audits and recertification every three years |
SOC 2 Type 2 and CMMC 2.0 control overlap
If you already have a SOC 2 Type 2 report, you’ve established a solid foundation for CMMC 2.0 compliance, particularly at Level 1 and Level 2. Reaching Level 3, however, will involve significant additional work to incorporate advanced cybersecurity measures, threat intelligence, and incident response. For companies that are already CMMC 2.0 certified, SOC 2 can complement their security posture, particularly if they handle customer data in industries outside of federal contracts.
Let’s take a look at SOC 2 control overlap and gaps for each level of CMMC 2.0.
SOC 2 Type 2 and CMMC Level 1
Level 1 is the most basic level of CMMC 2.0, focusing on protecting FCI through 17 foundational cybersecurity practices. SOC 2 Type 2 typically covers a substantial portion of Level 1 controls. For instance, both frameworks address:
- Access controls: SOC 2 aligns with CMMC Level 1’s requirements to limit information access based on role and need.
- Physical security: Controls around system access, password policies, and network protections are well covered in both frameworks.
- Incident response: Many SOC 2 Type 2 reports include an incident response mechanism, which aligns with Level 1’s requirements for basic incident handling.
There may be minor gaps in requirements specific to federal standards, such as the precise specifications for handling FCI. But overall, you’re likely very close to meeting Level 1 requirements with a SOC 2 Type 2.
SOC 2 Type 2 and CMMC Level 2
Level 2 is more rigorous, covering the same 17 practices in Level 1 plus an additional 93 practices from NIST SP 800-171 controls specific to CUI. Both SOC 2 Type 2 and CMMC 2.0 Level 2 include:
- Access control, risk management, and incident response: SOC 2’s Security and Confidentiality Trust Service Criteria overlap with CMMC’s requirements in these areas, especially for user authentication, access permissions, and risk assessments.
- Continuous monitoring and audit logs: SOC 2 generally covers logging and monitoring, which aligns with CMMC Level 2’s requirements for tracking and reviewing user activity.
- Configuration management: SOC 2 requirements often include system configuration and change management, which is essential for CMMC Level 2 compliance.
- Policy overlap: SOC 2 and CMMC Level 2 require documented policies that outline security practices around data security, access control, and incident response. Both frameworks expect policies to be well-documented, regularly reviewed, and enforced across the organization.
- Risk assessments: Both frameworks require organizations to conduct regular risk assessments. This includes identifying potential threats, vulnerabilities, and the impact of security incidents, as well as implementing controls to mitigate those risks.
- Security awareness training: For both CMMC and SOC 2, companies must conduct regular employee training on security policies and procedures and cybersecurity threats. CMMC may also require training on DoD-related data protection specifics for handling CUI.
Although there is a good amount of overlap, CMMC Level 2 introduces specific controls from NIST SP 800-171 that aren’t explicitly required for SOC 2. These include additional requirements for the handling and protection of media containing CUI, which may need extra measures beyond those covered by SOC 2. CMMC Level 2 also requires more stringent identification and access procedures tailored to protect CUI, which may require additional measures.
SOC 2 Type 2 and CMMC Level 3
Level 3 is the highest level of CMMC compliance and requires a more rigorous set of security practices that align more closely with NIST 800-172 than SOC 2 Type 2. While there is some control overlap in areas like continuous monitoring and incident response and everything else that was part of CMMC Level 2, Level 3’s focus on advanced persistent threats means SOC 2 Type 2 often leaves significant compliance gaps.
- Advanced threat detection and response: Level 3 demands advanced threat intelligence, response mechanisms, and proactive threat hunting capabilities that aren’t part of SOC 2.
- Zero-trust and network segmentation requirements: Level 3 controls require a high level of network segmentation and zero-trust principles, which aren’t standard in SOC 2.
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Deep Dive: CMMC 2.0 and ISO 27001
ISO 27001 is a globally recognized information security standard. While CMMC focuses on protecting FCI/CUI, ISO 27001 lays out best practices for building and maintaining an information security management system (ISMS) that protects any type of sensitive data — whether it's employee information, customer records, or intellectual property.
Like SOC 2, ISO 27001 compliance is voluntary but widely adopted by organizations that handle sensitive information. It’s seen as a mark of strong information security practices and can be a major advantage for companies looking to reassure clients about their data protection standards.
CMMC and ISO 27001 have a shared goal of protecting sensitive data, and both frameworks require companies to identify and address security risks. ISO 27001 takes a structured, risk-based approach that aligns well with CMMC 2.0’s requirements at Levels 2 and 3. Both frameworks also have control requirements for areas like access management, incident response, configuration management, and risk assessment.
What is the difference between ISO 27001 and CMMC?
While CMMC 2.0 and ISO 27001 both aim to secure sensitive data, CMMC is strictly about US federal defense data, making it mandatory for DoD contractors. ISO 27001 is broader, designed for any organization that wants a structured approach to information security and risk management.
CMMC is also more prescriptive, especially at higher levels, with specific requirements based on DoD needs. ISO 27001 is more about creating a robust, adaptable system for managing information security risks in any industry.
ISO 27001 has 93 controls — known as Annex A controls — grouped into 4 themes: Organizational Controls, People Controls, Physical Controls, and Technological Controls. Organizations choose the specific controls from those listed in Annex A they will implement to satisfy the core requirements of Clauses 4-10.
Like CMMC Levels 2 and 3, ISO 27001 also requires an external audit by an accredited certification body. Certification is valid for three years, with annual surveillance audits to ensure ongoing compliance.
Recommended reading
ISO 27001 Controls Explained: A Guide to Annex A
ISO 27001 and CMMC Control Overlap
If you already have ISO 27001 certification, you’re likely well on your way to meeting many of the requirements in CMMC 2.0. ISO 27001 emphasizes risk-based controls and aligns with many security best practices found in CMMC. Let’s examine overlaps by CMMC 2.0 compliance level.
ISO 27001 and CMMC Level 1
ISO 27001 compliance provides a solid foundation for the foundational security practices of CMMC Level 1. They cover many of the same control areas, including:
- Access controls: Both ISO 27001 and CMMC Level 1 require limiting access based on need-to-know principles.
- Security awareness training: ISO 27001 emphasizes user awareness and training, which aligns with CMMC Level 1’s requirements for basic security hygiene.
- Incident response and physical security: ISO 27001 includes incident response and physical security measures, which cover Level 1’s basic requirements.
Minor gaps may exist where ISO 27001 doesn’t explicitly address certain federal contracting requirements, and on the other hand CMMC doesn’t have ISMS requirements like ISO 27001, but generally speaking, an ISO 27001-certified organization is very close to meeting Level 1 requirements.
ISO 27001 and CMMC Level 2
CMMC 2.0 Level 2 expands on the 17 practices from Level 1 by adding 93 practices on CUI protection pulled from NIST SP 800-171. These requirements overlap with ISO 27001 in the following areas:
- Access controls, incident management, and security policies: ISO 27001’s Annex A controls align well with CMMC’s Level 2 practices, including user authentication, access control, and incident management.
- Risk assessment and treatment: ISO 27001 requires formal risk assessments, which corresponds well with CMMC Level 2’s focus on risk-based practices.
- Configuration and change management: Many ISO 27001-certified organizations implement configuration management controls, aligning with CMMC Level 2 requirements.
That said, CMMC Level 2 introduces specific controls from NIST SP 800-171 that ISO 27001 doesn’t explicitly require. For example, media protection and specific encryption standards for CUI may need additional controls, and Level 2 requires certain U.S. federal-specific standards around CUI that may not be directly covered in ISO 27001.
ISO 27001 and CMMC Level 3
Level 3 requires even more advanced practices, aligned with NIST SP 800-172. ISO 27001 lays a good foundation for risk assessment, ongoing monitoring, and incident response, which aligns with Level 3’s requirements. However, Level 3 expects more advanced and proactive security practices.
- Threat hunting and advanced cybersecurity practices: Level 3 emphasizes advanced threat detection, intelligence, and response, which ISO 27001 does not require.
- Zero trust architecture and network segmentation: Level 3 expects more granular network controls and zero-trust principles, which go beyond ISO 27001’s standards.
- Supply chain and external security: Level 3 includes expanded supply chain protections and external security practices, which ISO 27001 doesn’t cover in as much detail.
Like SOC 2 Type 2, ISO 27001 certification provides a substantial head start for CMMC 2.0 compliance, especially for Levels 1 and 2. However, Level 3 compliance will demand more extensive, specialized security controls not covered by ISO 27001.
Preparing your business for CMMC, SOC 2, and ISO 27001 compliance
GRC automation solutions offer an easier, more efficient way to manage compliance, whether you need to comply with one framework or many. Secureframe simplifies compliance for organizations navigating multiple frameworks, including CMMC 2.0, SOC 2, and ISO 27001. By leveraging common controls across these standards, Secureframe provides a clear view of how your specific controls satisfy requirements across multiple frameworks, reducing duplicate work and accelerating time-to-compliance.
Users can create custom frameworks, map controls to specific risks and compliance requirements, and edit mappings as needed, making Secureframe a dynamic, adaptable tool for evolving security and regulatory demands. 89% of Secureframe users say they accelerated time to compliance across multiple frameworks, and 92% reduced time spent on manual tasks.
To learn more about how Secureframe can support your CMMC 2.0, SOC 2, and ISO 27001 compliance, schedule a demo with our experts.
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FAQs
What is the difference between NIST and SOC 2?
NIST frameworks provide detailed, government-created security guidelines to manage cybersecurity risks and protect sensitive data, primarily for federal agencies and contractors. SOC 2 is an auditing standard developed by the AICPA to assess how well a company’s security controls protect client data and is used broadly across private industry.
What is the difference between ISO 27001 and CIS critical security controls?
ISO 27001 is an international standard that helps organizations establish, implement, maintain, and continually improve an information security management system (ISMS), providing a structured approach to managing risks. CIS Critical Security Controls is a set of 18 specific security controls developed by the Center for Internet Security, focusing on essential cybersecurity measures and best practices. While ISO 27001 provides a framework for managing security broadly, CIS controls are more tactical, detailing specific actions for immediate impact on security posture.