What Is a 3PAO? FedRAMP, CMMC and SCR CAP Assessors Compared

A 3PAO is a third-party assessment organization: an independent organization that assesses whether another organization meets a defined set of requirements. The term appears in FedRAMP, in CMMC (as C3PAO) and in the SCR Conformity Assessment Program (SCR CAP). Each program accredits its assessors differently and produces a different result.

What does 3PAO mean?

3PAO stands for Third-Party Assessment Organization. "Third party" means the assessor is independent of the organization being assessed and of the customers relying on the result. The SCF's 3PAO page defines a 3PAO as "an independent organization that assesses whether another organization meets a defined set of requirements."

The acronym is shared, but the programs are separate. A 3PAO accredited for one program is not automatically accredited for another.

How do FedRAMP, CMMC and SCR CAP 3PAOs differ?

Here is how the three uses compare:

1. FedRAMP 3PAO. Assesses cloud service offerings against the FedRAMP baselines so federal agencies can authorize them. FedRAMP 3PAOs are accredited through A2LA. [VERIFY: confirm current FedRAMP 3PAO accreditation process on fedramp.gov]
2. CMMC C3PAO. Assesses defense contractors against CMMC requirements derived from NIST SP 800-171. C3PAOs are authorized by The Cyber AB. [VERIFY: confirm current C3PAO authorization and accreditation language on cyberab.org]
3. SCR 3PAO. Assesses organizations under the SCR CAP using Secure Controls Framework (SCF) controls. According to the SCF, SCR 3PAOs "are entities accredited by The Cyber AB," which the SCF describes as "the official Accreditation Body for the SCR CAP." See the Cyber AB page.

The SCF Council chose The Cyber AB as the SCR CAP accreditation body, based on its world-wide recognition and impartiality.

What does an SCR 3PAO actually do?

The SCR CAP page describes a two-phase process:

1. First-Party Declaration (1PD). The organization self-assesses, defines its assessment boundary and Statement of Applicability, identifies its Minimum Security Requirements control set and prepares evidence.
2. Third-Party Assessment, Attestation and Certification (3PAAC). An accredited 3PAO examines, interviews and tests, then produces a Technical Assessment Report and an Executive Assessment Report.

The result is a Report on Conformity (ROC) with a designation. The SCR CAP offers a Law, Regulation and/or Framework (LRF) specific SCR Certification against one authority, such as NIST CSF 2.0, or a Tailored SCR Certification against a custom Minimum Security Requirements (MSR) control set. Assessments run at three rigor levels: Standard, Enhanced and Comprehensive.

Can one assessor cover SCR CAP, SOC 2 and ISO 27001?

In principle, one assessment hub can serve several outcomes, but only when the assessor holds every required credential.

• A SOC 2 report must be issued by a licensed CPA firm under AICPA attestation standards.
• An ISO 27001 certificate must be issued by a certification body accredited to certify ISO/IEC 27001.
• An SCR CAP certification requires a 3PAO accredited by The Cyber AB.

A SCR 3PAO that is also a licensed CPA firm, or also an accredited ISO 27001 certification body, could in theory run one SCF-based assessment and evidence set and then deliver the separate outputs. The SOC 2 report would still come from the CPA firm and the ISO 27001 certificate from the certification body. The SCR CAP itself does not issue SOC 2 reports or ISO 27001 certificates.

The efficiency comes from the SCF itself: one set of controls mapped to many laws, regulations and frameworks, so evidence is collected once. The SCF post comparing ISO 27001, SOC 2 and SCR CAP covers how to choose.

How do you find an SCR 3PAO?

SCR 3PAOs are listed through The Cyber AB's SCF Marketplace, which the SCF 3PAO page links to. Before you engage one, confirm three things:

1. The organization's current accreditation status for the SCR CAP.
2. Whether you need an LRF-Specific or Tailored certification, and which rigor level.
3. Whether you also need a SOC 2 report or ISO 27001 certificate, and whether the firm separately holds those credentials.

Frequently Asked Questions (FAQ)

What is the difference between a 3PAO and a C3PAO?

C3PAO is the CMMC term for a certified third-party assessment organization that assesses defense contractors. 3PAO is the general term and is also used by FedRAMP and the SCR CAP. Each program has its own accreditation.

Who accredits SCR 3PAOs?

The SCF states that SCR 3PAOs are accredited by The Cyber AB, the accreditation body for the SCR CAP.

Can an SCR 3PAO issue a SOC 2 report?

Only if the firm is also a licensed CPA firm, and then the SOC 2 report is issued under AICPA attestation standards as a separate output. The SCR CAP does not issue SOC 2 reports.

Is a FedRAMP 3PAO automatically an SCR 3PAO?

No. Accreditation is program-specific. A firm must be accredited by The Cyber AB to perform SCR CAP assessments.