Is My MSP Considered a Cloud Service Provider for CMMC?

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.