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External Service Providers — Official DoD FAQ

Is My MSP Considered a Cloud Service Provider for CMMC?

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Official DoD Answer
Source Source: DoD CIO CMMC FAQs v5 (E-Q5)

It depends on the relationships between the CSP, the MSP, and the Organization Seeking Assessment. If the cloud tenant is subscribed to the OSA, even if the MSP resells the service, the MSP is not a CSP. If the MSP contracts with the CSP and modifies the basic cloud service, then the MSP may be a CSP and must meet applicable FedRAMP requirements.

In-Depth Analysis

MSP vs CSP: It Depends on the Relationship

Whether your Managed Service Provider is also a Cloud Service Provider under CMMC depends on the specific contractual and technical arrangements.

When Your MSP Is NOT a CSP

If your organization directly holds the cloud subscription (e.g., you have the Microsoft 365 tenant license) and the MSP simply administers it on your behalf, the MSP is not a CSP. The actual cloud provider (Microsoft, AWS, etc.) is the CSP.

When Your MSP IS a CSP

If the MSP holds the cloud subscription in their name, modifies the basic cloud service, or provides a hosted solution built on cloud infrastructure, the MSP may be considered a CSP. In this case, the MSP's offering must meet FedRAMP Moderate baseline requirements.

Why This Matters

The distinction determines whether your MSP needs to meet FedRAMP requirements:

  • MSP only (not CSP): Assessed as ESP through your CMMC assessment
  • MSP that is also CSP: Must meet FedRAMP Moderate baseline or equivalency

Review your contracts carefully and consult with your assessor to determine the correct classification before your assessment.

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