Are CMMC Assessments Required for Organizations That Only Handle Hard-Copy CUI?

Hard-Copy CUI Is Still CUI

A common misconception is that CMMC only applies to digital systems. If you handle CUI in any form — including paper documents — you need CMMC compliance.

What This Means

Your CMMC assessment will include evaluation of:

• Physical security controls — locked storage, access controls to areas where CUI is handled
• Media protection — secure handling, transport, and destruction of paper CUI
• Personnel security — who has access to hard-copy CUI areas
• Visitor controls — managing access by non-cleared personnel

NIST 800-171 Controls That Apply

Several NIST SP 800-171 control families are directly relevant to hard-copy CUI:

• Physical Protection (PE): Limit physical access, protect physical environments
• Media Protection (MP): Protect, sanitize, and control media (including paper)
• Access Control (AC): Limit access to authorized users

Even if your entire digital environment is outsourced, if employees handle paper CUI (blueprints, technical manuals, correspondence), your organization is in scope for CMMC assessment.