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:
By the end, you will understand why a Customer Responsibility Matrix (CRM) is a must-have for CMMC Compliance and cybersecurity readiness.
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.
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.
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.
One of the biggest compliance risks is misalignment between assumed and actual responsibilities. Without a CRM, contractors may experience:
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Security vulnerabilities due to unassigned security measures
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Compliance failures from missing security controls
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Audit failures due to lack of documented accountability
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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).
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:
A Customer Responsibility Matrix (CRM) is directly tied to regulatory requirements, including:
| ✅ | CMMC 2.0 Final Rule – Mandates clear documentation of security responsibilities |
| ✅ | DFARS 252.204.7012 – Requires compliance with NIST SP 800-171, which emphasizes defined security roles |
CMMC auditors will often ask:
❓ “Who is responsible for implementing X security control?”
Without a CRM, contractors risk:
| ❌ | Unclear or undocumented responsibilities |
| ❌ | Compliance failures due to assumptions |
| ❌ | Failing CMMC audits |
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.
To ensure CMMC 2.0 compliance and NIST SP 800-171 alignment, every CRM should include the following five key components:
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:
By structuring the CRM around CMMC practices, organizations can track compliance progress and address gaps efficiently.
One of the most critical aspects of a CRM is defining who is responsible for each security control. This could be:
Example:
Clearly defining roles prevents assumed responsibility gaps and ensures every security measure is accounted for.
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:
A well-documented implementation plan ensures that security policies are properly executed before an audit.
A CRM should include a status column that tracks the real-time progress of each security control.
| ✅ | Implemented – Fully in place and compliant |
| 🟡 | In Progress – Partially implemented, pending verification |
| ❌ | Not Started – Requires immediate action to avoid compliance risks |
| CMMC Control | Security Practice | Responsible Party | Implementation Notes | Compliance Status |
| AC.L1-3.1.1 | Limit system access | Contractor IT Team | Define access roles, review quarterly | ✅ Implemented |
| AC.L2-3.1.5 | Least privilege | MSP and Contractor | MSP manages, contractor audits access logs | 🟡 In Progress |
| IA.L2-3.5.3 | Enforce MFA | MSSP | MFA enabled for all remote access users | ✅ Implemented |
Tracking compliance status helps contractors prioritize remediation efforts and ensures they are CMMC audit-ready.
Auditors will request proof of compliance during CMMC assessments. A CRM should include a column for supporting evidence, listing relevant:
Example Supporting Evidence:
Maintaining proper documentation in the CRM ensures smooth CMMC audits and provides clear proof of security measures.
Without a Customer Responsibility Matrix (CRM) in place, contractors risk compliance failures, security gaps, and failed audits due to unclear security responsibilities.
Even though these providers deliver essential security services, contractors cannot assume that compliance responsibilities are covered unless they are documented in a CRM.
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.
| ✅ | Request a CRM as Part of Service Agreements (MSA/SLA): Ensure that security responsibilities are explicitly outlined in contracts, service agreements, or statements of work (SOWs). |
| ✅ | Align the CRM with Your Organization’s CMMC Compliance Scope: Review which CMMC 2.0 controls apply to your environment and ensure third-party responsibilities are correctly mapped. |
| ✅ | Verify That the Provider’s Security Measures Are Documented and Auditable: Request evidence such as security policies, SOC reports, log management procedures, and incident response documentation. |
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.
Before creating a CRM, contractors must understand their security obligations under CMMC 2.0 and NIST SP 800-171.
| ✔️ | Conduct a CMMC/NIST 800-171 Gap Assessment: Identify which cybersecurity controls are already implemented and where there are gaps. |
| ✔️ | Determine Which Controls Require Third-Party Support: Contractors often rely on Managed Service Providers (MSPs), Managed Security Service Providers (MSSPs), and Cloud Service Providers (CSPs) for security functions. |
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.
Once you have identified which controls require third-party support, it is time to gather CRM documentation from your providers.
| ✔️ | Reach Out to All Security & IT Service Providers: Request a Customer Responsibility Matrix (CRM) from: |
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| ✔️ | Ensure the CRM Assigns Security Responsibilities: The CRM should explicitly outline which party is responsible for each cybersecurity control. |
Red Flag: If a provider cannot provide a CRM, they may not fully understand their role in CMMC compliance, creating potential audit risks.
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:
✔️ 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.
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
✔️ Review the CRM During CMMC Pre-Assessment Audits
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Clearly defines who is responsible for each security control
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Covers third-party services, cloud environments, and IT infrastructure
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Regularly reviewed & updated as cybersecurity policies evolve
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Integrated into incident response, access control, and risk management policies
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Serves as documentation proof for CMMC 2.0 and NIST SP 800-171 audits
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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.
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).
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.
Some CMMC security controls require both contractor and provider involvement, yet many organizations overlook these shared responsibilities.
Example:
Fix: Clearly outline shared responsibilities in the CRM and involve compliance & security teams to ensure clarity.
✔️ 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.
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
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.