CMMC Compliance for AI Systems

Understand CMMC 2.0 Requirements for AI

CMMC 2.0 defines three maturity levels. Defense contractors must achieve the appropriate level based on their contract requirements.

CMMC Level 1: Foundational

• Basic security practices for unclassified information
• AI-specific: Document AI systems handling controlled unclassified information (CUI), implement access controls, establish incident response

CMMC Level 2: Advanced/Intermediate

• Documented and repeatable security practices
• AI-specific: Formal AI governance documentation, security testing procedures, supply chain risk management for AI, employee training on AI security

CMMC Level 3: Optimized

• Proactive security practices with continuous improvement
• AI-specific: Advanced threat modeling for AI systems, continuous monitoring and improvement, sophisticated supply chain verification, advanced adversarial testing

Map AI Controls to CMMC Domains

CMMC 2.0 covers 15 domains. Map your AI systems to relevant domains:

• Access Control: Who accesses AI training data and models? Implement role-based controls.
• Asset Management: Inventory all AI systems, maintain asset registry, track model versions and training data sources.
• Incident Response: Document how you respond to AI security incidents (data breaches, adversarial attacks, unauthorized access).
• Risk Management: Conduct risk assessments for AI systems, identify vulnerabilities, document mitigations.
• Supply Chain Risk Management: Vet third-party AI vendors, verify their security practices, document procurement requirements.
• Situational Awareness: Monitor AI system performance for degradation, anomalies, or security indicators.

Implement AI-Specific Security Safeguards

Beyond standard CMMC controls, implement AI-specific protections:

• Model Security: Protect model files from unauthorized access or modification. Use version control and integrity verification.
• Training Data Protection: Encrypt sensitive training data, implement data loss prevention, maintain provenance tracking.
• Adversarial Defense: Test models for robustness against adversarial inputs. Document defensive measures.
• Audit Trails: Log all access to AI systems, model training activities, prediction queries involving CUI.
• Segmentation: Isolate AI systems handling CUI from other networks. Implement network-level controls.

Conduct Internal Audit and Gap Assessment

Before pursuing certification, audit your current state against CMMC requirements:

• Document your AI systems inventory and CUI handling
• Review existing security controls and their AI applicability
• Identify gaps in documentation, technical controls, or processes
• Prioritize remediation based on criticality and complexity
• Create remediation timeline with assigned ownership

Pursue CMMC Certification

Once ready, engage a Licensed Assessor Organization (LAO) to conduct your official assessment:

• Pre-Assessment: Assessor reviews your documentation and systems
• Assessment Activities: Interviews, observation, testing of controls
• Evidence Review: Detailed examination of logs, records, and security implementations
• Certification: Upon successful assessment, you receive CMMC certification valid for three years
• Continuous Monitoring: Maintain compliance and annual self-assessments