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Assessments — Official DoD FAQ

Does a Joint Venture Need Its Own CMMC Status?

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Official DoD Answer
Source Source: DoD CIO CMMC FAQs v5 (C-Q6)

If a Joint Venture (JV) is a separate legal entity with its own information systems that process, store, or transmit FCI or CUI, the JV will need its own CMMC assessment and status. If the JV uses the information systems of one of its partners and those systems are already covered under that partner's CMMC assessment, a separate assessment for the JV may not be necessary.

In-Depth Analysis

CMMC for Joint Ventures

The answer depends on how your Joint Venture is structured and which information systems it uses.

Scenario 1: JV Has Its Own Systems

If the JV operates as a separate legal entity with its own IT infrastructure that handles FCI or CUI, it needs its own CMMC assessment and status. This is the most common scenario for large JVs.

Scenario 2: JV Uses a Partner's Systems

If the JV exclusively uses the information systems of one of its member companies, and those systems are already covered under that partner's CMMC assessment boundary, a separate JV assessment may not be needed. The partner's CMMC status covers those systems.

Best Practice

When forming a JV for DoD work, address CMMC requirements early in the teaming agreement. Document which partner's systems will be used, ensure those systems are within the partner's CMMC assessment scope, and confirm this arrangement with the Contracting Officer before proposal submission.

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