Overview of CMMC Policy: Title 32 and Title 48
The Department of Defense (DoD) has implemented Cybersecurity Maturity Model Certification (CMMC) requirements through two distinct regulatory frameworks: Title 32, CMMC Program, and Title 48, Assessing Contractor Implementation of Cybersecurity Requirements, of the Code of Federal Regulations.
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Title 32
Title 32 governs the programmatic aspects of CMMC implementation, establishes the CMMC Program structure, including assessment procedures, scoring methodology, and certification pathways.
Title 32:
- Defines CMMC levels and assessment criteria
- Establishes the role of CMMC Third-Party Assessor Organizations (C3PAOs)
- Applies to all DoD contractors who process, store, or transmit CUI
- Sets the baseline for cybersecurity readiness across the supply chain

Title 48
Title 48 integrates CMMC requirements into the Defense Federal Acquisition Regulation Supplement (DFARS). This rule governs how CMMC is enforced through contracts, specifying when and how certification must be demonstrated during the acquisition process. Title 48 ensures that cybersecurity compliance is a condition of contract award, and it provides the legal framework for incorporating CMMC clauses into solicitations and agreements.
Title 48:
- Mandates CMMC certification as a prerequisite for contract eligibility
- Details how contracting officers evaluate and verify compliance
- Aligns cybersecurity with procurement and acquisition strategy
- Supports enforcement through DFARS clauses and contract terms