When it comes to the Cybersecurity Maturity Model Certification (CMMC), understanding the regulatory landscape is crucial. Two major aspects of the Code of Federal Regulations—Title 32 and Title 48—constitute the legal and contractual foundation for the implementation of CMMC across the federal government.
But what do each of them do, and why are they important?
Title 48: Where Compliance Meets Contracts
Title 48, known as the Federal Acquisition Regulations (FAR), is what most contractors think of when they hear “CMMC compliance.” It governs how the federal government purchases goods and services, including cybersecurity requirements in contracts.
Here’s what Title 48 includes:
- Establishes the rules for government procurement, including DoD contracts.
- Describes how CMMC assessments and certifications are included in contract language.
- Includes both FAR and DFARS, the two sets of regulations that govern DoD acquisitions
- Grants the legal authority to enforce CMMC requirements in federal contracts
Did you know? A rule finalized in January 2025 expanded Title 48’s reach, now applying CUI protections and NIST 800-171 requirements across all federal agencies, not just the DoD.
Title 32: The Policy Engine Behind CMMC
While Title 48 pertains to contracts, Title 32 grants the Department of Defense the authority to define and enforce cybersecurity policies—like CMMC—across its contractors.
Here’s what Title 32 entails:
- Governs Department of Defense security policies and procedures.
- Authorizes implementation of the CMMC framework
- Establishes how Controlled Unclassified Information (CUI) must be protected (via NIST SP 800-171)
- Establishes the baseline requirements for cybersecurity within the Defense Industrial Base (DIB)
Consider Title 32 the “what” and “why” behind CMMC. It defines the standards. Title 48 represents the “how.” It incorporates those standards into your contracts.
Title 32 and Title 48 equal CMMC enforcement.
In summary, Title 32 defines what must be protected and how (DoD security policies). Title 48 describes how it gets enforced in contracts (FAR/DFARS regulations). Together, they create the legal backbone for CMMC enforcement across the Defense Industrial Base and, soon, the broader federal contracting space. Both titles play a crucial role in ensuring the proper integration and enforcement of CMMC within the federal acquisition process.
Together, these two regulations:
- Define the cybersecurity requirements you must fulfill (Title 32)
- And enforce them through government contracts (Title 48).
Understanding both is crucial for any federal contractor—especially as CMMC expands across all agencies and becomes a cornerstone of future acquisitions.
Need help navigating CMMC requirements?
Tego is here to guide you through scoping, readiness, and certification.
Learn more at tegodata.com/cmmc or schedule a call with our team today.