Written By Paige Langmead
Secure CUI and Meet Federal Cybersecurity Requirements
For federal contractors managing Controlled Unclassified Information (CUI), CMMC compliance is mandatory—not optional. Many defense contractors ask whether Microsoft 365 can support their compliance efforts. The answer is yes, but only the correct version, Microsoft 365 Government Community Cloud High (GCC High), provides the required capabilities and assurances.
What Is Microsoft 365 GCC High?
Microsoft 365 GCC High is a dedicated cloud environment designed for U.S. federal agencies and contractors subject to strict regulations, including ITAR, FedRAMP High, and DFARS 252.204-7012. Unlike commercial Microsoft 365, GCC High provides:
- Elevated security and compliance controls
- U.S.-only data residency
- Management by background-screened U.S. personnel
These features make it suitable for storing and processing CUI in accordance with CMMC Level 2 and NIST SP 800-171.
How GCC High Supports CMMC Domains
Microsoft 365 GCC High includes capabilities that directly align with CMMC Level 2 domains:
Access Control (AC):
Azure AD Conditional Access, Multi-Factor Authentication (MFA), and Role-Based Access Control (RBAC) enforce least privilege, controlled remote access, and separation of duties (AC.L2 objectives).
Audit and Accountability (AU):
Microsoft Purview and Microsoft Defender for Office 365 provide audit logging, user activity monitoring, and alerts, meeting AU.L2 requirements.
Incident Response (IR):
Integration with Microsoft Defender for Endpoint and Microsoft Sentinel enables automated threat detection, incident logging, and response workflows—supporting IR.L2 controls.
System and Communications Protection (SC):
FIPS 140-2 validated encryption for data at rest and in transit supports SC.L2 controls for secure communication and boundary protection.
Identification and Authentication (IA):
Azure AD with integrated MFA ensures authenticated user access and session control in line with IA.L2 requirements.
GCC High Is Not a Complete Compliance Solution
While GCC High covers a substantial portion of technical CMMC requirements, organizations remain responsible for:
- Developing policies, procedures, and user training
- Implementing physical security controls (e.g., facility access)
- Performing operational tasks like log review, account management, and vulnerability remediation
GCC High provides the platform and tools, but compliance depends on how these tools are implemented, configured, and governed in your System Security Plan (SSP).
Why Commercial Microsoft 365 Falls Short
Many contractors assume commercial Microsoft 365 can be secured for CUI—but it cannot meet federal compliance requirements:
- Data may reside outside the continental U.S.
- Support personnel may not be U.S. citizens
- Lacks FedRAMP High and DoD SRG Impact Level 4/5 authorizations
If your contract includes DFARS 252.204-7012 clauses or involves CUI, commercial Microsoft 365 is not compliant. In these cases, GCC High or another secure government-authorized enclave is required.
Executive Takeaways
Achieving CMMC compliance is a shared responsibility between the cloud provider and the contractor. Microsoft 365 GCC High provides a secure foundation for storing and processing CUI, but compliance success depends on:
- Proper configuration of technical controls
- Documentation in the System Security Plan (SSP)
- Ongoing governance and monitoring
Migrating to GCC High is not just a compliance step—it is a strategic decision for federal contractors managing sensitive information.
Call to Action (Lead Generation)
Need help achieving CMMC compliance with Microsoft 365 GCC High?
Our team helps federal contractors:
- Assess your current Microsoft 365 environment
- Configure GCC High for CMMC Level 2 compliance
- Document and maintain policies and procedures
- Train users and ensure ongoing governance
👉 Schedule a free consultation today to ensure your Microsoft 365 deployment meets DoD CMMC requirements and protects your CUI.