Shared Responsibility in the Cloud: What CMMC Requires vs. What Cloud Providers Actually Cover
Cloud adoption has transformed how organizations deploy, scale, and secure IT systems, but for Department of Defense (DoD) contractors, it has also introduced a dangerous misconception: that cloud providers handle compliance for your organization. When it comes to CMMC compliance, that assumption can be costly.
Understanding the shared responsibility model is critical to meeting CMMC requirements and avoiding compliance gaps that could derail certification.
What the Shared Responsibility Model Really Means
Cloud providers such as AWS, Azure, and Google Cloud secure the cloud itself: the physical data centers, underlying infrastructure, and foundational services. Customers, however, are responsible for securing what they place in the cloud. In other words:
- The cloud provider ensures the platform’s availability and resilience
- You are accountable for how systems are configured, accessed, monitored, and protected
CMMC assessors do not accept “our cloud provider handles that” as a valid control implementation.
What Cloud Providers Typically Cover
Most major cloud providers are responsible for:
- Physical security of data centers
- Hardware lifecycle management
- Core infrastructure availability
- Baseline platform security controls
- FedRAMP authorization (for specific services)
While FedRAMP alignment is important, it does not equate to CMMC compliance.
What CMMC Still Requires from the Customer
Under CMMC, especially at Level 2, organizations remain responsible for implementing and demonstrating controls across domains such as:
- Identity and access management (least privilege, MFA, role enforcement)
- Secure system configuration and hardening
- Logging, monitoring, and alerting
- Incident response planning and testing
- Risk assessments and POA&M management
- Asset inventory and boundary definition
- Data protection for CUI across systems, users, and workflows
Even in a fully cloud-hosted environment, you own these controls and must provide supporting evidence.
Common Cloud Compliance Gaps for CMMC
From a technical perspective, many organizations fail CMMC readiness reviews due to:
- Misconfigured cloud services
- Incomplete logging and retention
- Poorly defined boundaries between in-scope and out-of-scope systems
- Lack of documented procedures aligned with actual cloud operations
- Assuming CSP documentation replaces customer responsibility
These gaps often go unnoticed until late in the readiness review process, when remediation is more expensive and time-consuming.
How Tego Helps as a CMMC RPO
As a CMMC Registered Provider Organization (RPO), Tego helps organizations bridge the gap between cloud capabilities and CMMC requirements. We don’t just assess, we operationalize compliance.
Tego’s CMMC Cloud Support Includes:
- Cloud architecture reviews mapped directly to CMMC practices
- Shared responsibility mapping: CSP vs. customer controls
- Secure configuration and hardening guidance
- Boundary definition and data flow validation
- Evidence development aligned with assessor expectations
- Risk assessments and POA&M creation
- Policy, procedure, and technical control alignment
Our team understands both cloud engineering and CMMC requirements, ensuring that controls are not only implemented but also defensible in assessments.
Cloud platforms are powerful enablers, but they do not absolve organizations of responsibility under CMMC. Compliance depends on how systems are configured, managed, and governed, not on their hosting location.
With Tego as your CMMC RPO, you gain a partner who understands the shared responsibility model, knows what assessors look for, and helps you build a secure, compliant, and audit-ready cloud environment.
Cloud-smart. Compliance-ready. Be CMMC compliant with Tego. Get started today.