Compare

CMMC vs ATO: how they differ, side by side

How CMMC and ATO differ: what each is, who owes it, when it applies and who enforces it.

CMMCBinding on DoD contractors through contract

ATOBinding on federal agencies; reaches vendors through contracts

Checked21 Oct 2026

01 / Side by side

CMMC and ATO, side by side

	CMMC	ATO
What it is	regulation	other
Jurisdiction	United States (federal)	United States (federal)
Legal force	Binding on DoD contractors through contract	Binding on federal agencies; reaches vendors through contracts
Status	Partly in force	In force
Applies from	10 Nov 2025	28 Jul 2016
Who owes it	Defense contractors and subcontractors that process, store or transmit Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) on contractor systems.	Federal agencies, which must authorize each information system before use; vendors and contractors whose systems process agency data go through the agency's process.
Enforcement	DoD contracting officers (no award without required status); false affirmations can bring False Claims Act liability (treble damages plus per-claim penalties) and suspension or debarment.	OMB oversight, inspector general audits and annual FISMA reporting to Congress; no civil penalties. Systems without an ATO should not operate.

02 / CMMC

What CMMC requires

Applies to AI systems as to any system: AI tools, models or cloud AI services that process FCI or CUI fall inside the assessed boundary and must meet the same controls.

01Level 1: annually self-assess against the 15 FAR 52.204-21 safeguarding requirements and affirm in SPRS.
02Level 2: meet the 110 NIST SP 800-171 Rev. 2 requirements, by self-assessment or C3PAO assessment every three years.
03Level 3: hold Level 2 certification plus a government (DIBCAC) assessment of 24 NIST SP 800-172 requirements.
04Post results in SPRS and have a senior official affirm compliance annually.
05Give the contracting officer the CMMC unique identifiers (UIDs) for systems handling FCI or CUI and report any changes to them during performance (DFARS 252.204-7021(e), NOV 2025).
06Flow down the required CMMC level to subcontractors handling FCI or CUI.

03 / ATO

What ATO requires

Applies to AI systems as to any system: an AI model, AI-enabled application or AI cloud service used by an agency needs an authorization decision covering its data flows, and changes such as new models or data sources can trigger reassessment.

01Designate senior officials (authorizing officials) to formally authorize systems and common controls.
02Complete an initial authorization for each system, based on explicit risk acceptance, before it becomes operational.
03Categorize the system, select and implement NIST SP 800-53 controls, and assess them before authorization.
04Continuously monitor controls and move to ongoing authorization when eligible.
05Reauthorize systems on a time-driven or event-driven basis as risk changes.

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

SOURCES