Prompt Injection: AI’s Biggest Security Risk

Only one of these three vendors sells a FedRAMP-authorized identity platform you can buy today as a defense contractor, one sells two of them, and one sells none. Whether that matters for your CMMC Level 2 assessment depends entirely on whether your identity provider stores, processes, or transmits Controlled Unclassified Information (CUI), or provides security protections for the systems that do. That second condition is where most contractors get the analysis wrong. The IdP question is arguably the most argued-about scoping decision in CMMC 2.0 Level 2 preparation, because an identity provider almost never holds CUI directly, yet it controls access to everything that does. This article works through the regulatory requirement, the actual FedRAMP status of JumpCloud, Okta, and Microsoft Entra ID, and how to choose based on your CUI architecture rather than vendor marketing. Understanding the CMMC Level 2 + FedRAMP Requirement What CMMC Level 2 Requires for Cloud Services Handling CUI CMMC 2.0 Level 2 requires contractors to implement the 110 security requirements of NIST SP 800-171 Rev. 2 and, for most contracts, pass a third-party assessment by a Certified Third-Party Assessor Organization (C3PAO). The 48 CFR acquisition rule took effect on November 10, 2025, which means CMMC clauses now appear in new Department of Defense (DoD) solicitations, with third-party assessment requirements expanding through the phased rollout in 2026 and beyond. The cloud piece comes from the CMMC program rule at 32 CFR Part 170. If an Organization Seeking Certification uses a Cloud Service Provider (CSP) to process, store, or transmit CUI, that cloud service offering must be either FedRAMP Authorized at the Moderate baseline or higher or must meet security requirements equivalent to the FedRAMP Moderate baseline. Your C3PAO verifies this during the assessment. If your in-scope CSP fails the test, you fail the assessment. The DFARS 252.204-7012 “FedRAMP Moderate or Equivalent” Clause The requirement predates CMMC. DFARS 252.204-7012 has required since 2016 that any external CSP used to store, process, or transmit covered defense information meet security requirements “equivalent to those established by the Government for the Federal Risk and Authorization Management Program (FedRAMP) Moderate baseline.” For years, “equivalent” was undefined, and contractors interpreted it loosely. The DoD CIO closed that door with its December 2023 equivalency memo. To be FedRAMP Moderate Equivalent, a CSP must now demonstrate 100% compliance with the FedRAMP Moderate baseline, validated by a FedRAMP-recognized Third-Party Assessment Organization (3PAO), and hand over a full Body of Evidence to the contractor. No open Plans of Action and Milestones (POA&Ms) against the baseline are permitted. In some ways, it’s stricter than authorization itself, since authorized CSPs are allowed to carry POA&Ms. Important: A vendor telling you they are “NIST 800-171 compliant” or “aligned to FedRAMP controls” does not satisfy DFARS 7012 or the CMMC rule. Either the offering appears on the FedRAMP Marketplace at Moderate or higher, or the vendor gives you a 3PAO-attested Body of Evidence demonstrating full equivalency. Anything else is a gap your C3PAO will find. When an Identity Provider Falls Under This Requirement An IdP is a cloud service. The question is whether it processes, stores, or transmits CUI. In a typical SSO flow, the IdP handles credentials, authentication tokens, session data, and directory attributes. None of that is CUI in most environments. So a literal reading says the FedRAMP mandate doesn’t apply. The complication is the CMMC scoping guidance, which defines Security Protection Assets (SPAs): assets that provide security functions to the CMMC assessment scope even if they never touch CUI. An IdP enforcing multi-factor authentication (MFA), conditional access, and session policy over your CUI enclave is the textbook SPA. SPAs are in scope for your assessment and get evaluated against the relevant NIST SP 800-171 requirements they help satisfy. Let Axipro help you build a business continuity plan that’s practical, compliant, and audit-ready. Schedule Your Free Assessment Today Schedule A Consultation Does Your Identity Provider Actually Need to Be FedRAMP Authorized? When the IdP Processes, Stores, or Transmits CUI Some architectures do push CUI through the identity layer. If usernames or directory attributes contain CUI (think program names or export-controlled project identifiers), if your IdP proxies application traffic through a gateway that carries CUI payloads, or if CUI-bearing documents get attached to identity workflows, the IdP is now a CSP handling CUI. FedRAMP Moderate or equivalent becomes non-negotiable. When the IdP Provides Security Protections for CUI (SPA Role) This is the common case, and it’s genuinely gray. The FedRAMP requirement in the rule text attaches to CSPs that process, store, or transmit CUI. A pure-play authentication service that does neither is an SPA, not a CUI-handling CSP. Under the final CMMC rule, External Service Providers (ESPs) that handle only Security Protection Data, such as configuration data, logs, and credentials, do not themselves require FedRAMP authorization or a separate CMMC certification. Their services get assessed as part of your assessment. In practice, C3PAOs are not uniform on this. Some accept a well-documented System Security Plan (SSP) showing the IdP never touches CUI. Others take a conservative view that authentication data for CUI systems is sensitive enough that they want FedRAMP-grade assurance behind it, and they will probe hard. DIBCAC’s historical position, given publicly by officials as far back as 2020, is that clouds with management access to CUI systems don’t need FedRAMP unless CUI actually moves into them. That position helps, but you carry the burden of proving CUI never transits the service. Cases Where a Commercial IdP May Be Acceptable A commercial, non-FedRAMP IdP can survive a CMMC Level 2 assessment when all three of the following are true: CUI demonstrably never touches the IdP, the IdP is documented as an SPA with the specific 800-171 requirements it supports, and the data flows in your SSP prove the boundary. This is exactly how many contractors run enclave strategies, keeping a commercial identity stack for the corporate network while the CUI enclave uses its own FedRAMP-authorized identity. The “External Service Provider” (ESP) Classification Under CMMC The final