×

Simplifying CMMC: Understanding Your Boundary in Microsoft Azure Government

10-Jul 2025 Ashley Lex

Author: Ashley Lex 

In our previous LinkedIn Pulse post, we emphasized that defining your CUI boundary is the most important first step toward CMMC Level 2 readiness. In this article, we’re zooming in on what that means specifically within Microsoft Azure Government (GCC or GCC High) environments. Azure Government is a FedRAMP approved platform used by many federal contractors, often with the assumption that FedRAMP alone guarantees CMMC compliance.

Azure Government ≠ Automatic Compliance

Azure Government, GCC, and GCC High are all FedRAMP authorized environments. This means they are approved to store, process, and transmit Controlled Unclassified Information (CUI). However, FedRAMP authorization doesn’t automatically make your organization CMMC compliant.

CMMC is about your implementation of security controls, not just the platform’s capabilities. It’s your responsibility to define the boundary, configure the environment securely, and provide evidence to a C3PAO that all 320 Level 2 control objectives are met.

Let’s break down what CMMC readiness looks like in the Microsoft Government cloud.

Step 1: Get Qualified for Azure Government

Before you can use Microsoft’s Government services, contractors must verify their eligibility via the online Azure Government Onboarding Form.

You’ll need to provide details like your Commercial and Government Entity (CAGE) code to determine eligibility. Once approved, you can procure licenses through a Microsoft Government-authorized reseller.

It’s important to understand what Microsoft services you’ll need, whether it’s:

  • Microsoft 365 GCC/GCC High (i.e., for email, Teams, SharePoint)
  • or Azure Government (i.e., for hosting VMs, databases, and web applications)

Step 2: Implement the Right Controls — and Know Who Owns What

Once you’re operating in a government cloud environment, the next step is to implement the CMMC Level 2 controls. Microsoft provides a strong baseline of security capabilities but remember: Compliance is a shared responsibility.

Review the Microsoft Shared Responsibility Matrix to understand:

  • Which controls are owned by Microsoft (e.g., physical security of data centers)
  • Which controls are shared (e.g., patch management, logging)
  • Which controls are your responsibility (e.g., access control policies, incident response plans)

This matrix is available upon request from Microsoft and is something your C3PAO will expect to see during the assessment.

Step 3: Leverage Automation to Validate and Monitor Compliance

Once you’ve implemented the required security services (e.g., endpoint protection, threat detection, log analysis), it’s time to validate that they meet CMMC Level 2 requirements.

Using a tool like the Securitybricks CMMC Accelerator to scan your Azure GCC or GCC High environment will instantly validate your control implementation. This accelerator will cut the guess work out of your compliance, significantly reduce manual effort involved in continuous monitoring, and give your team real-time visibility into your CMMC compliance status.

Other key features include:

  • Automated technical control checks for Azure workloads
  • Over 700 checks mapped to the 320 CMMC Level 2 objectives for M365
  • Evidence collection built into the instance
  • Remediation guidance for failed controls
  • Dashboards to visualize compliance posture
  • Built-in SPRS scoring to prioritize non-POA&M-eligible controls

Using Azure Government is a great first step, but it’s just the beginning. For CMMC Level 2 compliance, you’ll also need to document:

  • Which Azure subscriptions, resource groups, or workloads are in scope.
  • Which assets store, transmit, or process CUI.
  • How access is managed (e.g., users, service principals, external identities).
  • How boundary controls are implemented (e.g., firewalls, NSGs, Azure Policy).
  • Which third-party services or APIs are integrated, and whether they’re also compliant.

Conclusion

CMMC compliance starts with boundary clarity. It is absolutely achievable—but only when you’re intentional about your architecture, documentation, and tooling. Azure Government can support your CMMC journey, but it’s not a “plug and play” solution. Your boundary must be clearly defined, documented, and defended with evidence aligned to the 320 control objectives.