Customer Responsibility Matrix (CRM): A Key to CMMC Compliance

The Importance of a Customer Responsibility Matrix (CRM) in CMMC 2.0 Compliance

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is a critical framework designed to protect Controlled Unclassified Information (CUI) across the Defense Industrial Base (DIB). With evolving cybersecurity threats and strict Department of Defense (DoD) regulations, defense contractors must implement robust security measures to safeguard sensitive data. 

However, CMMC 2.0 compliance is not a solo effort. Most contractors rely on Managed Service Providers (MSPs), Managed Security Service Providers (MSSPs), and Cloud Service Providers (CSPs) to handle IT infrastructure, security operations, and compliance tasks. While these third-party providers offer essential cybersecurity services, contractors must not assume that compliance responsibilities are automatically covered. Instead, security duties must be documented to ensure CMMC audit readiness. 

This is where the Customer Responsibility Matrix (CRM) becomes invaluable. A CRM defines cybersecurity responsibilities between a contractor and its third-party service providers, ensuring that each security control is properly assigned. Without a well-documented CRM, contractors may face compliance gaps, audit failures, and increased security risks due to unclear or overlapping responsibilities. 

In this guide, we will explore: 

• How a CRM aligns with CMMC 2.0 requirements 
• Why it is essential for regulatory compliance 
• How contractors can develop and implement an effective CRM 

By the end, you will understand why a Customer Responsibility Matrix (CRM) is a must-have for CMMC Compliance and cybersecurity readiness. 

What is a Customer Responsibility Matrix (CRM)?

Before diving into how to implement a CRM, it is important to first understand what it is and why it is essential for CMMC 2.0 compliance. 

A Customer Responsibility Matrix (CRM) is a structured document that clearly defines who is responsible for implementing, managing, and maintaining specific cybersecurity controls. In the context of CMMC 2.0 and NIST SP 800-171, a CRM serves as a critical tool for contractors and their external service providers (e.g., MSPs, MSSPs, and Cloud Providers) to clarify security responsibilities and prevent compliance gaps.

1. Ensures a Clear Division of Responsibilities

Without a well-defined CRM, contractors may assume third-party providers are handling certain security controls when in reality, these tasks remain unassigned or misunderstood. A CRM eliminates confusion by explicitly mapping security responsibilities to the appropriate entity, whether it is the contractor, MSP, MSSP, or Cloud Provider.

2. Essential for CMMC 2.0 and NIST SP 800-171 Compliance

For CMMC Level 2 certification, contractors must comply with 110 security controls outlined in NIST SP 800-171. Many of these cybersecurity requirements involve shared responsibilities between internal IT teams and third-party service providers, making a CRM essential for proving compliance during audits. 

3. Reduces Security Gaps and Compliance Risks 

One of the biggest compliance risks is misalignment between assumed and actual responsibilities. Without a CRM, contractors may experience: 

A Customer Responsibility Matrix (CRM) is not just a document, it is a cybersecurity and compliance roadmap that helps contractors remain aligned, audit-ready, and fully accountable for securing Controlled Unclassified Information (CUI). 

How Does a Customer Responsibility Matrix (CRM) Fit into CMMC 2.0 Compliance?

Now that we have covered what CRM is and why it is important, let’s explore how it fits into the CMMC 2.0 framework. 

Since CMMC certification is divided into three levels, the role of a CRM varies depending on the compliance level: 

CRM Relevance Across CMMC 2.0 Levels 

• Level 1 (Foundational): Minimal Need for CRM 
  • Organizations follow basic cybersecurity hygiene practices
  • Most security responsibilities fall directly on the contractor, meaning a CRM is less critical 
• Level 2 (Advanced – NIST SP 800-171): CRM is Essential 
  • Contractors must implement 110 security controls under NIST SP 800-171 
  • Many contractors outsource security tasks to MSPs, MSSPs, and Cloud Providers 
  • A CRM ensures responsibilities are divided between internal teams and third-party providers 
• Level 3 (Expert – NIST SP 800-172): High-Impact Security Requires a Well-Documented CRM 
  • Designed to defend against Advanced Persistent Threats (APTs) 
  • Contractors must formally document and track all security responsibilities, making a CRM non-negotiable 
    

CRM and Regulatory Compliance 

A Customer Responsibility Matrix (CRM) is directly tied to regulatory requirements, including: 

CRM and Audit Readiness: Avoiding Compliance Pitfalls 

CMMC auditors will often ask: 

❓ “Who is responsible for implementing X security control?” 

Without a CRM, contractors risk: 

A well-documented CRM is essential for passing CMMC 2.0 audits, ensuring that cybersecurity responsibilities are clearly assigned, documented, and regularly reviewed. 

A Customer Responsibility Matrix (CRM) is essential for meeting CMMC 2.0 requirements, ensuring clear accountability, compliance, and audit readiness. Contractors working with third-party providers must maintain an up-to-date CRM to secure Controlled Unclassified Information (CUI) and pass compliance assessments with confidence. 

Key Components of a Customer Responsibility Matrix (CRM)

A Customer Responsibility Matrix (CRM) is more than just a compliance checklist, it is a detailed roadmap that assigns cybersecurity responsibilities between a contractor and their third-party providers (MSPs, MSSPs, CSPs). Without a well-structured CRM, organizations risk compliance gaps, security misconfigurations, and failed CMMC audits. 

To ensure CMMC 2.0 compliance and NIST SP 800-171 alignment, every CRM should include the following five key components: 

1. CMMC Practice/Control Reference

Each CRM should map directly to specific CMMC 2.0 and NIST SP 800-171 security controls. This ensures that every requirement is covered and aligned with audit expectations. 

Example: 

• CMMC Control: AC.L1-3.1.1 – Authorized Access Control 

• Requirement: Limit information system access to authorized users 

By structuring the CRM around CMMC practices, organizations can track compliance progress and address gaps efficiently. 

2. Responsible Party: Who Owns Each Security Control? 

One of the most critical aspects of a CRM is defining who is responsible for each security control. This could be: 

• The Contractor (internal IT/security team) 

• A Managed Service Provider (MSP) 

• A Managed Security Service Provider (MSSP) 

• A Cloud Service Provider (CSP) like Microsoft Azure or AWS 

• A shared responsibility between multiple entities 

Example: 

• CMMC Control: AC.L2-3.1.5 – Least Privilege 

• Responsible Party: MSP manages privileged access; Contractor reviews access logs 

Clearly defining roles prevents assumed responsibility gaps and ensures every security measure is accounted for. 

3. Implementation Details: How Are Security Controls Applied? 

Beyond whom is responsible, a CRM must define how security measures are implemented. This provides clarity on technical execution and ensures alignment with CMMC security requirements. 

Example: 

• CMMC Control: IA.L2-3.5.3 – Multi-Factor Authentication (MFA
• Implementation Details
  • MSP/MSSP enforces MFA policy at the system level
  • Contractor ensures all employees enable MFA and receive cybersecurity training

A well-documented implementation plan ensures that security policies are properly executed before an audit. 

4. Compliance Status 

A CRM should include a status column that tracks the real-time progress of each security control. 

Tracking compliance status helps contractors prioritize remediation efforts and ensures they are CMMC audit-ready. 

5. Supporting Evidence: Documentation for Audits 

Auditors will request proof of compliance during CMMC assessments. A CRM should include a column for supporting evidence, listing relevant:

• Policies & Procedures (e.g., access control policies) 
• Configuration Logs (e.g., firewall rules, MFA settings) 
• Security Reports (e.g., vulnerability scans, audit logs) 
• Training Records (e.g., user awareness training, phishing simulations) 

Example Supporting Evidence: 

• CMMC Control: SI.L1-3.14.1 – Flaw Remediation 
• Evidence Required: Antivirus logs, endpoint protection reports, security patch records 

Maintaining proper documentation in the CRM ensures smooth CMMC audits and provides clear proof of security measures. 

Why Contractors Must Obtain a CRM from Third-Party Providers

In today’s cybersecurity landscape, most Defense Industrial Base (DIB) contractors rely on third-party providers—such as Managed Service Providers (MSPs), Managed Security Service Providers (MSSPs), and Cloud Service Providers (CSPs)—to handle critical IT and security functions. While these providers play a crucial role in securing networks and data, CMMC 2.0 compliance remains the contractor’s ultimate responsibility. 

Without a Customer Responsibility Matrix (CRM) in place, contractors risk compliance failures, security gaps, and failed audits due to unclear security responsibilities. 

1. Third-Party Providers & Their Role in Compliance 

• MSPs & MSSPs – Handle network security, monitoring, incident response, and threat detection 
• Cloud Service Providers (CSPs) – Manage infrastructure security, access controls, data encryption, and logging 

Even though these providers deliver essential security services, contractors cannot assume that compliance responsibilities are covered unless they are documented in a CRM. 

2. Common Mistake: Assuming “The Provider Handles Security” 

One of the biggest compliance mistakes contractors make is assuming that their MSP, MSSP, or CSP is handling all security requirements. Many CMMC 2.0 security controls are shared responsibilities between the contractor and the provider. 

Example Mistake: 

A contractor believes their MSP enforces multi-factor authentication (MFA), but during a CMMC audit, they discover that enforcing MFA for user access was their responsibility—resulting in non-compliance. 

To avoid misunderstandings and compliance failures, contractors must request and maintain a CRM from all third-party providers. 

3. Best Practices for Obtaining a CRM from Third-Party Providers 

How to Develop and Implement a Customer Responsibility Matrix (CRM)

A Customer Responsibility Matrix (CRM) is a crucial tool for ensuring CMMC 2.0 compliance, as it clearly defines who is responsible for which security controls between a contractor and their third-party providers. Without a well-developed CRM, organizations risk security gaps, compliance failures, and failed audits. 

Follow these four essential steps to create a CMMC-compliant CRM and ensure your organization is fully prepared for audits and assessments. 

Step 1: Identify Your Security Responsibilities 

Before creating a CRM, contractors must understand their security obligations under CMMC 2.0 and NIST SP 800-171. 

Map out which security controls fall under your responsibility vs. your third-party providers. 

Example: The contractor manages user access control policies, but the MSSP monitors and logs privileged access events. 

Step 2: Request and Review CRM from Your Service Providers 

Once you have identified which controls require third-party support, it is time to gather CRM documentation from your providers. 

Red Flag: If a provider cannot provide a CRM, they may not fully understand their role in CMMC compliance, creating potential audit risks. 

Step 3: Align the CRM with Internal Policies 

A CRM should not exist in isolation—it must be fully integrated into your organization’s cybersecurity and compliance policies. 

✔️ Incorporate the CRM into Internal Security Policies: Ensure alignment with: 

• • Incident Response Plan (who responds to cyber threats?) 
  • Access Control Policies (who enforces user authentication and authorization?) 
  • Risk Management Procedures (who handles security assessments and remediations?) 

✔️ Assign Internal Personnel for Oversight: Designate a compliance officer or cybersecurity lead responsible for monitoring third-party compliance. 

Example: Your CRM should align with your incident response plan, specifying who investigates security alerts—the MSSP or the internal IT team. 

Step 4: Regularly Update the CRM 

A CRM is a living document that should evolve alongside your security policies, third-party relationships, and compliance requirements. 

✔️ Update the CRM When Security Responsibilities Change 

• • If your organization switches MSSPs, adds new cloud services, or updates security policies, the CRM must reflect those changes. 

✔️ Review the CRM During CMMC Pre-Assessment Audits 

• • Before undergoing a CMMC 2.0 assessment, auditors will check if all security responsibilities are documented. 
  • Conduct internal CRM reviews at least quarterly to stay CMMC audit ready. 

Checklist for a Strong CRM Implementation 

Common Pitfalls in CRM Implementation and How to Avoid Them

A Customer Responsibility Matrix (CRM) is a powerful tool for ensuring CMMC 2.0 compliance, but common mistakes can lead to security gaps, compliance failures, and failed audits. Below are the top CRM pitfalls contractors face and how to fix them before they become a problem. 

Pitfall #1: Assuming Your MSP/MSSP Handles All Compliance Needs 

One of the biggest misconceptions contractors make is assuming their Managed Service Provider (MSP) or Managed Security Service Provider (MSSP) is fully responsible for CMMC compliance. 

The Reality: While MSPs and MSSPs provide critical security services (e.g., monitoring, endpoint protection, SIEM, and incident response), ultimate compliance responsibility still falls on the contractor. 

Fix: Always verify which CMMC controls are covered by your provider by reviewing your CRM and Service Level Agreements (SLAs). 

Pitfall #2: Failing to Obtain a CRM Before a CMMC Audit 

Without a documented CRM, contractors may struggle to prove compliance during a CMMC audit, leading to delays or even assessment failure. 

The Risk: Auditors often ask, “Who is responsible for implementing X security control?” If the answer isn’t documented, the contractor may fail that requirement. 

Fix: Request a CRM from all third-party providers well before your CMMC audit. Conduct internal reviews to ensure responsibilities are properly assigned. 

Pitfall #3: Ignoring Shared Responsibilities 

Some CMMC security controls require both contractor and provider involvement, yet many organizations overlook these shared responsibilities. 

Example: 

• Multi-Factor Authentication (MFA): The MSSP enforces MFA at the system level, but the contractor must ensure all employees enable it. 
• Incident Response: The MSSP detects and alerts, but the contractor must follow an internal incident response plan. 

Fix: Clearly outline shared responsibilities in the CRM and involve compliance & security teams to ensure clarity. 

Quick Fixes for a Stronger CRM Implementation 

✔️ Review Provider SLAs for Security Responsibility Coverage: Ensure that all CMMC-relevant security tasks are formally assigned. 

✔️ Conduct Quarterly Reviews of CRM Documentation: Regularly update the CRM to reflect changes in security responsibilities. 

✔️ Involve Compliance & Security Teams in CRM Validation: Ensure that the CRM aligns with CMMC, DFARS, and NIST SP 800-171 compliance. 

Final Thoughts: A Well-Defined CRM is Critical for CMMC Compliance

As cyber threats evolve and CMMC 2.0 compliance becomes mandatory for defense contractors, having a clear and structured Customer Responsibility Matrix (CRM) is no longer optional; it is essential. A CRM ensures cybersecurity responsibilities are properly assigned, reducing the risk of compliance failures, security gaps, and audit issues. 

A well-documented CRM helps contractors: 

✅ Clearly define security roles between internal teams and third-party providers (MSPs, MSSPs, CSPs). 

✅ Avoid compliance gaps that can lead to CMMC audit failures. 

✅ Enhance cybersecurity readiness by ensuring accountability across all security functions. 

Next Steps: Strengthen Your CRM for CMMC Compliance 

• Review your existing CRM documentation and ensure it aligns with CMMC 2.0 and NIST SP 800-171 controls. 
• Request a CRM from your MSP, MSSP, or cloud provider to clarify third-party security responsibilities. 
• Regularly update your CRM to reflect new security policies, service provider changes, or compliance updates. 

If you need expert guidance in implementing or improving your CRM, MAD Security can help! 

Contact MAD Security today to ensure your CRM is CMMC-compliant, audit-ready, and fully optimized for cybersecurity success. 

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