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Implementation — Official DoD FAQ

Can Non-U.S. Citizens Be Part of the CMMC Ecosystem?

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Official DoD Answer
Source Source: DoD CIO CMMC FAQs v5 (D-Q4)

Yes, non-U.S. citizens and organizations can participate in the CMMC Ecosystem as authorized C3PAOs, Registered Practitioners, or other CMMC professional roles, subject to the requirements and vetting processes established by the Cyber AB and CAICO.

In-Depth Analysis

International Participation in CMMC

The CMMC ecosystem is open to qualified international participants, reflecting the global nature of the defense industrial base.

Roles Open to Non-U.S. Citizens

  • C3PAO (Assessment Organization): Non-U.S. organizations can seek C3PAO authorization through the Cyber AB
  • CCA (Certified Assessor): Individual assessors can be non-U.S. citizens
  • CCP (Certified Professional): Advisory professionals are not limited by citizenship
  • RP (Registered Practitioner): Consulting roles are open internationally

Considerations

While citizenship is not a barrier to CMMC ecosystem participation, all participants must meet the same vetting, training, and certification requirements. There may be additional considerations for handling certain types of CUI that have export control restrictions (ITAR/EAR).

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