CMMC vs SOC 2: when a SaaS or IT services company needs which
If your company sells SaaS or IT services to defense customers and asks whether SOC 2 is enough, the short answer is no. SOC 2 is a commercial attestation under the AICPA framework, and it does not satisfy CMMC. CMMC applies to you only when you fall inside a defense contractor's assessment scope, which happens when you store, process or transmit CUI or security protection data (such as log and configuration data) on your assets. Under 32 CFR 170.4, a provider that touches neither is not an external service provider for CMMC purposes, and a SOC 2 report alone will not change that. Many providers pursue both, because SOC 2 serves commercial buyers and CMMC serves the defense contracts that depend on the provider's scope.
Two pivot questions decide most of the analysis. First, does your environment store, process or transmit CUI or security protection data? Map the data flows with your defense customer, not only your product architecture, since log pipelines and management consoles often carry security protection data. Second, if you offer a cloud service that would hold CUI, does it meet the FedRAMP Moderate baseline or equivalent requirements under 32 CFR 170.16(c)(2) and 170.17(c)(5)? A SOC 2 report does not establish FedRAMP authorization. Ask each defense customer in writing which ESP or cloud requirements their contract imposes, and which assessment type is the minimum.
Write down the answers before you buy an audit. If the answer to the first question is no and the cloud question does not arise, SOC 2 may cover your commercial needs and your defense customer's flow-down questions may need only a written scope statement. If the answer is yes, confirm with your customer whether a voluntary ESP certification assessment would reduce their assessment effort, which 32 CFR 170.19(c)(2)(ii) allows. Also confirm the current CMMC status with the DoW CIO's CMMC page, since the program's phase schedule has changed recently and the eCFR text may lag the official guidance.
How CMMC and SOC 2 differ on scope, standard and proof
This table compares who requires each program, the control basis each one tests, the proof it produces, the period it covers and who may receive the result. Read it as a sorting tool: if a defense customer's contract requires CMMC, SOC 2 cannot replace it, and if a commercial customer asks for SOC 2, a CMMC assessment will not satisfy that request.
| Dimension | CMMC (Level 2) | SOC 2 |
|---|---|---|
| Who requires it | Defense contracts that handle CUI, with the requirement set by the contract and the DFARS clauses | Commercial customers and buyers who ask for an independent controls report, usually chosen by the service organization |
| Control basis | The 110 Level 2 requirements, which are identical to NIST SP 800-171 Rev. 2 under 32 CFR 170.14(c)(3) | The 2017 Trust Services Criteria: 61 criteria, including 33 common criteria, with Security always in scope |
| Proof produced | A CMMC status posted in SPRS after a self-assessment or C3PAO certification, plus an annual affirmation by a senior official | An attestation report from a CPA firm containing a Type 1 opinion on control design or a Type 2 opinion on operating effectiveness |
| Period covered | A point-in-time assessment that must be renewed every three years, with annual affirmations in between | Type 1 covers a single date; Type 2 covers a period, and the period length is a judgment the service auditor makes |
| Who may receive the result | Results are recorded in SPRS and assessed by the DoD or the contracting office, not published to the public | SOC 2 reports are generally restricted to specified users, while a SOC 3 is a general use report that can be freely distributed |
| Scope of the assessed system | The CUI environment and the external service providers that process, store or transmit CUI or security protection data | The system described by management, including the services, infrastructure and controls in that description |
| Ask before you start | Confirm with your contracting officer which CMMC level and assessment type your contract requires, since the DoD suspended Phase II in July 2026 | Confirm with your buyers whether they need a Type 1 or Type 2 report and which Trust Services Criteria categories they expect |
Where SOC 2 evidence and CMMC work overlap
Teams with a SOC 2 report and a defense contract often assume one answers the other. The supplied mapping sources show that the two share themes, but a mapping is a starting point for verification, not proof that a SOC 2 report establishes CMMC conformance.
Mapping lists are not equivalence
The CIS Controls Navigator lists both SOC 2 and CMMC v2.0 among its mapped frameworks, so a control can be traced across both. A mapping shows where two frameworks point at similar practices, not that satisfying one satisfies the other. Ask your assessor which CMMC objectives your SOC 2 evidence actually addresses, and document any gaps.
Revision mismatch in NIST mappings
NIST's CSF 2.0 Reference Tool links its informative references to SP 800-171 Rev. 3, while CMMC Level 2 still assesses the Rev. 2 requirements. Any crosswalk you build from the CSF tool will point at different requirement text than your CMMC assessment uses. Confirm which revision each mapping cites before you reuse it as evidence.
Who checks non-NIST mappings
NIST develops some informative references but does not check the correctness of mappings developed by non-NIST entities, and listing a mapping does not imply endorsement. Treat any SOC 2 to CMMC crosswalk from a vendor or consultant as unverified until you test its claims against the assessment objectives in NIST SP 800-171A.
Access control evidence
Access control is a shared theme: SOC 2 common criteria cover logical access, and CMMC has access control requirements in its AC domain. The auditors test different things, though. A SOC 2 Type 2 report tests operating effectiveness over a period, while CMMC requires each objective to be met with evidence in final form. Check whether your user access reviews, privileged account records and removal procedures meet both sets of expectations.
Logging and monitoring evidence
Audit logging appears in both frameworks as a theme, and a logging stack built for a SOC 2 examination may not hold the records CMMC asks for. Confirm which systems are in CMMC scope, where their logs are retained, and whether the same log sources cover the systems described in your SOC 2 system description. Scope mismatches are the usual reason evidence cannot be reused.
Change management evidence
Change management maps to SOC 2 system operations criteria and to CMMC configuration management practices. Both expect documented approvals, testing and rollback records. Verify that change tickets for CUI systems carry the approvals and dates your CMMC assessor will sample, not only the ones that were gathered for the SOC 2 examination.
When a provider falls in a contractor's CMMC assessment
A provider falls in a contractor's CMMC assessment only when it is an external service provider whose assets touch CUI or security protection data. Under 32 CFR 170.4, an ESP is an external person, technology or facility that provides or manages IT or cybersecurity services. The definition then narrows: the provider counts only if CUI or security protection data, such as log and configuration data, is processed, stored or transmitted on its assets. A SaaS vendor or managed service provider that never touches the contractor's CUI or its security logs sits outside the assessed boundary. A provider that hosts a ticketing system holding CUI, or that ships security logs from the contractor's environment, sits inside it. The contractor's CMMC asset inventory and scoping decisions drive this outcome, so the first task is to map where CUI and security protection data actually flow, including support access and backups.
Scope is decided by the contractor, but the provider's position affects the contractor's effort. Under 32 CFR 170.19(c)(2)(ii), an ESP may voluntarily undergo a CMMC certification assessment to reduce the effort its customers spend during their own assessments, and the customer's contract sets the minimum assessment type the provider must hold. Ask each in-scope provider whether it holds a CMMC assessment, which level and which type, and read the contract clause before assuming a SOC 2 report will satisfy the contractor's assessor. A SOC 2 report answers a commercial question and does not replace the CMMC assessment objectives for the controls the provider operates on the contractor's behalf.
Cloud offerings holding CUI at Level 2 must be FedRAMP Authorized at the Moderate baseline or higher, or meet equivalent requirements under DoD policy. Under 32 CFR 170.16(c)(2) and 170.17(c)(5), this condition applies to any cloud offering the contractor uses for CUI. Confirm the exact authorization status, baseline and package name on the FedRAMP Marketplace rather than relying on a vendor's marketing statement, and check whether the authorization covers the specific service the contractor buys. If the provider holds no FedRAMP authorization and the equivalency route is claimed, get the DoD equivalency basis in writing from the provider and from the contracting officer. Start this review before the contract's assessment type is fixed, because a change of cloud provider later affects the contractor's SPRS posture and scope.
Sequencing CMMC and SOC 2 work to share evidence
This sequence lets a provider scope its CUI and security protection data once, build evidence that answers the CMMC objectives, and then reuse that evidence in a SOC 2 examination without treating the attestation as a substitute for CMMC.
Confirm CUI and security protection data flows
Start by mapping where CUI and security protection data (such as log and configuration data) are processed, stored or transmitted, including every system, tenant and administrative path. Under 32 CFR 170.4, a provider counts as an external service provider only if it handles these data on its assets, so this map decides whether the provider sits in a contractor's assessment at all. The owner is the contractor's compliance lead together with the provider's engineering and security leads. The step is complete when each flow has a named system owner and a documented yes or no on ESP status, confirmed with the customer's contract team where the answer is unclear.
Define the CMMC assessment boundary
Using the flow map, draw the CMMC boundary around the assets that process, store or transmit CUI and the assets that provide security protection for them. Document which external service providers sit inside that boundary and which sit outside it, since 32 CFR 170.19 governs how scoping decisions are recorded. Shared identity, logging and ticketing platforms need an explicit decision, because they can fall inside the boundary even when the core product does not. The step closes with a signed scope statement and an asset inventory that the assessor can trace back to the flow map.
Build SP 800-171A-aligned evidence in final form
Write evidence against the Level 2 requirements, which 32 CFR 170.14(c)(3) sets as identical to NIST SP 800-171 Rev. 2, and test each requirement against the assessment objectives in NIST SP 800-171A. A requirement is MET only when every applicable objective is satisfied with evidence in final form, so drafts, unsigned procedures and screenshots without dates do not count. The owner is the security team with the system administrators who run each control. The step is complete when each requirement ID in the CMMC Model has a traceable artifact, a named owner and a review date that falls within the assessment period.
Identify shared controls and evidence owners
Compare the CMMC evidence set with the controls that the SOC 2 examination will test against the common criteria CC1 to CC9, and mark which artifacts serve both. Access reviews, change tickets, vulnerability management records and incident procedures often overlap, but a control that appears in both sets still needs to satisfy the CMMC objective in its own terms. Record each overlap in a crosswalk that names the CMMC requirement ID, the TSC criterion and the single evidence source. The step is complete when the crosswalk is reviewed by both the CMMC assessor and the SOC 2 service auditor, or by the internal owners who will brief them.
Set the SOC 2 scope and categories
Decide which of the five Trust Services Categories (security, availability, processing integrity, confidentiality and privacy) belong in the SOC 2 scope. Security is always covered through the common criteria, while the other four add criteria only when the customer or the business needs them. Confirm with the CPA firm which systems fall within the system description, which is prepared against the AICPA 2018 description criteria. The step is complete when the scope and categories are written into the engagement letter and the system description draft matches the CMMC boundary wherever the same systems are involved.
Plan the Type 2 observation period
If the customer expects a Type 2 report, set an observation period long enough for the service auditor to opine on operating effectiveness, which the Journal of Accountancy notes has no generally accepted minimum. Schedule control operation so that evidence is generated throughout the period, not only at the end, and ask the CPA firm to confirm the period length in writing. A Type 1 report covers control design as of a single date and does not satisfy an operating effectiveness expectation. The step is complete when the period, the sampling approach and the evidence calendar are agreed and matched to the CMMC review cycle.
Reuse SOC 2 evidence without replacing CMMC objectives
When the SOC 2 examination runs, share evidence drawn from the same systems, but keep the CMMC assessment objectives as the test for CUI-scoped controls. A SOC 2 report can inform the assessor's understanding of a control, but it does not satisfy a CMMC objective on its own, and the assessor will still review the artifacts against SP 800-171A. The provider should confirm with its contracting customer and the C3PAO, where one is used, how far SOC 2 evidence is accepted. The step is complete when each reused artifact is linked to the CMMC objective it supports, and the open gaps are listed in a single register that both audit teams can read.
Maintain the evidence set between assessments
Keep the crosswalk, scope statement and evidence calendar current after each examination, since the CMMC Level 2 assessment must be repeated every three years and the annual affirmation in SPRS depends on continued compliance. Update the boundary when systems, tenants or service providers change, and record each change with its effect on both the CMMC scope and the SOC 2 system description. The step is complete when a named owner reviews the set on a fixed internal schedule and can show that every change was evaluated against both frameworks.
What drives the cost and cadence of each audit
The cost of a CMMC Level 2 assessment and a SOC 2 examination are paid to different people for different work, so compare quotes by component, not by headline total. For CMMC, the final rule estimated a Level 2 C3PAO certification assessment plus initial affirmation at $112,345 per assessment for an other-than-small entity and $101,752 for a small entity, and three-year totals, including two annual affirmations, at $117,768 and $104,670. These are the rule's estimates, not quotes. For SOC 2, the Justice Department's regulatory analysis for its October 2024 proposed rule cited vendor-sourced estimates of $5,000 to $25,000 for a Type 1 audit and $30,000 to $100,000 for a Type 2 audit. Those figures come from a different rulemaking and cover the CPA fee only, so they do not include your internal evidence work or remediation.
The recurring cost differs as much as the one-time cost. A CMMC Level 2 cycle runs three years, with an annual affirmation by a senior Affirming Official in SPRS after each assessment, and the assessment lapses if that affirmation is missed. A SOC 2 Type 2 report covers an observation period, and the report is refreshed on the period you agree with the CPA firm. Ask each vendor which costs repeat each year (evidence collection, tooling, auditor time, re-testing after remediation) and which are one-time (scoping, gap remediation, initial readiness). Confirm the current assessment type with the DoD contract before budgeting, because the Department of War suspended CMMC Phase II on 13 July 2026, and the DoW CIO About CMMC page should be checked for the current position.
When requesting quotes, ask each provider to state scope in writing: the systems and people in the CUI or SOC 2 boundary, the number of external service providers included, the assessment type, the observation period for SOC 2, and whether re-assessment after a failed control is included. Ask for the fee per assessment and per annual affirmation separately, the expected staff hours from your side, and what triggers an additional charge. Where one evidence set can serve both audits, ask whether the assessor will accept it, since the scope and the criteria differ.
CMMC vs SOC 2 questions buyers ask before hiring help
Does a SOC 2 report satisfy CMMC for our defense contracts?
No. A SOC 2 report is a commercial attestation over a service organization's controls under the AICPA's Trust Services Criteria, and it does not verify the requirements that CMMC Level 2 assesses. Level 2 uses 110 requirements, identical to NIST SP 800-171 Revision 2 under 32 CFR 170.14(c)(3), and each must be met with final evidence against the NIST SP 800-171A assessment objectives. Some records, such as access reviews, change tickets and logs, may serve both programs, but an assessor must check each one against the CMMC objective it supports. Ask your contracting officer which CMMC level your contract requires, and ask your CPA firm whether its report scope includes the systems that handle CUI.
Do our cloud and IT service providers need their own CMMC certification?
Only some of them, and the test is what data they touch. Under 32 CFR 170.4, an external service provider counts as an ESP only if CUI or security protection data, such as log and configuration data, is processed, stored or transmitted on its assets. A provider in that position falls within your CMMC assessment scope. Under 32 CFR 170.19(c)(2)(ii), an ESP may voluntarily undergo a certification assessment to reduce its effort during customers' assessments, and your contract sets the minimum assessment type it must meet. Confirm with your contracting officer which of your IT or security services touch CUI or security protection data, then ask each provider whether it holds a current certification and which assessment type it has.
Does a cloud provider holding CUI need FedRAMP Moderate authorization?
For Level 2 cloud offerings that hold CUI, yes, unless the provider meets equivalent security requirements under DoD policy. Under 32 CFR 170.16(c)(2) and 170.17(c)(5), the cloud offering must be FedRAMP Authorized at the Moderate baseline or higher on the FedRAMP Marketplace. A SOC 2 report does not satisfy this condition by itself. Check the Marketplace listing for the exact service and baseline, and ask the provider whether that authorization covers the specific service your team uses. Confirm with your contracting officer whether equivalency is accepted for your contract before you rely on it.
What does each audit cost, and how long does the work take?
Costs depend on who is paid for what, and the figures below come from different sources and years, so treat them as reference points rather than quotes. The DoD's final CMMC rule estimated $112,345 for a Level 2 C3PAO certification assessment plus initial affirmation for an other-than-small entity, and $101,752 for a small entity, with three-year totals of $117,768 and $104,670 including two annual affirmations. The Justice Department's regulatory analysis, citing vendor publications, put a SOC 2 Type 1 audit at $5,000 to $25,000 and a Type 2 audit at $30,000 to $100,000. The main drivers are system scope, the number of CUI assets, evidence readiness and the Type 2 observation period. No supplied source gives a duration, so ask each auditor for a written timeline. Also confirm how the July 2026 suspension of Phase II affects your certification timing.
What evidence do we need to provide for each audit?
The two audits ask for different proof. For a SOC 2, the CPA firm will expect a system description prepared against the AICPA's 2018 description criteria (DC 200), written representations from management under AT-C section 205, and, for a Type 2 report, evidence that controls operated across the review period. For CMMC Level 2, the assessor needs evidence in final form, not drafts, that satisfies each applicable NIST SP 800-171A objective, and a senior Affirming Official must affirm continuing compliance in SPRS after each assessment and annually after that. The overlap is largest in access reviews, change records and logs, but each set must be mapped to the criteria or objectives it supports. Ask the CPA firm for its evidence request list and the assessor for its objective-by-objective worksheet before you collect anything.
Can our internal team prepare for these audits without an outside partner?
Your team can do much of the preparation, but some parts must come from authorized outside parties. A SOC 2 report must be issued by a CPA firm, because SOC is a suite of services that CPAs may provide. For CMMC, the DoW CIO page says Phase 1 may only require self-assessments at Levels 1 and 2, while a Level 2 certification assessment, where required, must be performed by a C3PAO and Level 3 by DCMA DIBCAC. Internal staff can inventory systems, write the system description, map controls and gather evidence, which is often the largest share of the work. DeployOpen plans, implements, documents and prepares systems and evidence for compliance assessments, but it does not issue audit reports or certifications. Confirm with your contractor and assessor which steps they require before you decide.
Is CMMC Phase II still in effect for our contracts?
Not as originally scheduled. On 13 July 2026 the Department of War suspended CMMC Phase II, which had been set to start 10 November 2026 and would have required Level 2 C3PAO certification for applicable contracts, and it started a 60-day review by a CMMC Reform Task Force. Phase I self-assessments, SPRS postings, annual affirmations and DFARS 252.204-7012 obligations remain in place. The DoW CIO page, as of 17 October 2026, says implementation is paused in Phase 1, while the eCFR text of 32 CFR 170.3(e) still shows the original four-phase schedule. Because the dates are moving, confirm with your contracting officer which level and assessment type each solicitation requires and whether it applies NIST SP 800-171 Rev. 2 in the interim.
What the work needs from your team
Start by naming the people who will carry this work before any scoping begins. For CMMC, a senior Affirming Official must affirm continuing compliance in SPRS after each assessment and annually after that, and the assessment lapses if that annual affirmation is not made. For SOC 2, management must make written representations to the service auditor, which is why the system description and the control owners need an accountable executive sign-off. Confirm with your own counsel and contract team who holds these authorities, because the executive who signs the representation is taking personal responsibility for accuracy. Next, assign a system owner for the boundary and the asset inventory. In a CMMC assessment, the question of which assets handle CUI or security protection data drives the scope, and in a SOC 2 examination the system description must match what actually runs. One person should own that inventory and keep it current when services, regions or subprocessors change.
Controls must operate, not only be documented. Both audits test evidence over time: a SOC 2 Type 2 report opines on operating effectiveness across a period, and a CMMC requirement is MET only when all applicable assessment objectives in NIST SP 800-171A are satisfied with evidence in final form, not drafts. Give named staff responsibility for keeping evidence final, dated and retrievable, such as access review records, change tickets and log samples. Test a sample of each recurring control with your own team before any external assessor arrives, and record the gaps as a remediation list with owners. Confirm with your assessor which evidence format and retention they expect. Outside help can prepare evidence, map controls, run readiness reviews and document the system, but it does not issue audit reports or certifications. Only an independent auditor issues a SOC 2 report, and only an authorized C3PAO or DCMA DIBCAC assessment issues CMMC outcomes, so budget internal time for the people who will answer assessor questions.
How DeployOpen prepares readiness for both frameworks
DeployOpen plans, implements, documents and supports self-hosted open-source platforms inside your own cloud accounts, data centers or air-gapped networks. For CMMC vs SOC 2 work, we prepare the systems, controls and evidence that an independent assessor or auditor will examine, and we do not issue audit reports, attestations or certifications ourselves.
How we scope
- Agree a written scope that lists the systems, enclaves and external service providers in the CMMC or SOC 2 boundary
- Confirm which CUI or security protection data flows touch each in-scope platform before work starts
- Record which assessment type your contracts or customers require, so the scope matches that requirement
How we build
- Configure controls against NIST SP 800-171 Rev. 2 requirements or the SOC 2 criteria selected for your system
- Test each control against the assessment objectives or criteria it is meant to satisfy, and record the results
- Document configuration baselines, access rules and logging so evidence can be reproduced by an assessor
How we hand over
- Deliver control documentation, system descriptions and an evidence index mapped to each in-scope requirement
- Hand over runbooks for operating the platforms, including access reviews, change records and backup procedures
- Walk your internal team and assessor through the evidence so they can answer questions about how controls operate
How we support
- Offer ongoing support, upgrades and continuous testing as a retainer after the initial engagement
- Keep evidence current between assessments so each review period has records in final form
- Confirm with your assessor or auditor which evidence they require, since the final determination rests with them
