ISMS Copilot
ISMS Copilot

ISMS Copilot for CMMC and NIST 800-171

Draft your SSP, POA&M, and 110 NIST 800-171 controls — for the documentation, not for the CUI.

Read this first: ISMS Copilot is not FedRAMP authorized — keep CUI out of chats

ISMS Copilot is not FedRAMP authorized and is not on DoD's CC SRG / DISA approved provider list. CUI (Controlled Unclassified Information), CDI (Covered Defense Information), and any data subject to DFARS 252.204-7012 must not be entered into ISMS Copilot. What ISMS Copilot does well: drafting your System Security Plan (SSP), Plan of Action and Milestones (POA&M), and the policies for all 110 NIST 800-171 Rev. 2 controls. What it cannot do: be the system that stores or processes the CUI itself. Contractor-owned systems follow NIST 800-171. An external cloud that holds covered defense information needs security equivalent to the FedRAMP Moderate baseline under DFARS 252.204-7012. That is not the same as this product being FedRAMP authorized.

NIST 800-171 + CMMC framework details

What ISMS Copilot does for DoD contractors and subs

  • Draft a complete SSP covering all 110 NIST 800-171 Rev. 2 controls for CMMC Level 2, or the 15 Level 1 security requirements in FAR 52.204-21
  • Generate a POA&M template and walk through prioritization of unmet controls
  • Map your environment against each NIST 800-171 family (Access Control, Audit, Configuration Management, Incident Response, etc.)
  • Prepare for CMMC Level 1 self-assessment or Level 2 third-party assessment (C3PAO)
  • Cross-walk NIST 800-171 to NIST 800-53 Moderate baseline for primes that ask for both
  • Train staff on CUI handling, FCI vs CUI distinction, and incident reporting requirements

Built for the DIB compliance lead

Full NIST 800-171 Rev. 2 control library (110 controls, 14 families)

CMMC Level 1 (15 FAR 52.204-21 security requirements) and Level 2 (110 NIST 800-171 Rev. 2 requirements) coverage

DFARS 252.204-7012 incident reporting workflow (72-hour clock to DC3)

FCI vs CUI handling guidance

CMMC C3PAO assessment preparation checklists

NIST 800-53 Moderate cross-mapping for primes requiring NIST RMF

Integration with NIST 800-171A assessment objectives

Level 1 and Level 2 are different programs

CMMC Level 1 is FCI, FAR 52.204-21, 15 security requirements, self-assessment, and no POA&M. CMMC Level 2 is CUI, NIST 800-171 Rev. 2 (not Rev. 3), 110 requirements, a C3PAO or a specified self-assessment, and the POA&M bars in 32 CFR 170.21. Do not treat Level 1 as a smaller Level 2. As of 13 July 2026, DoD has suspended Phase II C3PAO assignment; Phase I self-assessments remain in force.

CMMC Level 1 vs Level 2

Frequently Asked Questions

What is the difference between CMMC Level 1 and Level 2?

They are different programs, not two sizes of the same one. Level 1 is FCI, FAR 52.204-21, 15 security requirements, self-assessment, and no POA&M. Level 2 is CUI, NIST 800-171 Rev. 2, 110 requirements, a C3PAO (or a specified self-assessment), and the POA&M bars in 32 CFR 170.21. As of 13 July 2026, DoD has suspended Phase II, so new designations are Level 1 (Self) or Level 2 (Self). The long-form walk is /learn/cmmc-level-1-vs-level-2.

Can I store CUI in ISMS Copilot?

No. ISMS Copilot is not FedRAMP authorized and is not on the DoD CC SRG approved list. Storing or processing CUI in ISMS Copilot would be a DFARS 252.204-7012 violation. Use a FedRAMP Moderate or higher environment for the actual CUI; use ISMS Copilot for the documentation that surrounds it.

Will ISMS Copilot get FedRAMP authorized?

Not on the current roadmap. FedRAMP authorization requires a US-government-only environment, JAB or agency sponsorship, and a multi-year process. ISMS Copilot's value proposition is documentation acceleration, not being the CUI system itself.

Is ISMS Copilot useful for CMMC Level 1?

Yes — and L1 is the easier case because the 17 L1 practices map directly to FAR 52.204-21 basic safeguarding, and self-assessment is allowed. ISMS Copilot drafts the L1 policies, the FCI handling SOP, and the annual self-attestation workflow.

How does this differ from NIST 800-53?

NIST 800-171 is for non-federal systems handling CUI (i.e. you, the contractor). NIST 800-53 is for federal systems (i.e. the agency). 800-171 is essentially a tailored subset of 800-53 Moderate. ISMS Copilot covers both, and our /frameworks/nist-800-53 page is the right starting point if your prime requires the full 800-53 baseline.

What about ITAR / export-controlled data?

ITAR-controlled technical data has the same rule as CUI plus stricter restrictions: must stay on US-person, US-soil systems with strict access control. ISMS Copilot runs entirely on EU infrastructure (Fly.io regions in the EU, Mistral on Sweden, AWS Frankfurt and Amsterdam), which is not an ITAR-cleared environment. Same pattern as CUI: use ISMS Copilot for the documentation, not for the data.

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