CMMC scoping

CMMC Enclaves Explained

A CMMC enclave is a segmented environment where CUI is processed, stored and transmitted, separated from the rest of the business. A well-drawn enclave can shrink what an assessment covers. It does not reduce what is required inside it: all 110 NIST SP 800-171 Rev. 2 requirements still apply to the enclave.

By Doug Majewski, President, Athena Consulting Group, LLC · Last reviewed: October 19, 2026

How scoping works under 32 CFR 170.19

32 CFR 170.19 sorts Level 2 assets into five categories:

  • CUI Assets — process, store or transmit CUI.
  • Security Protection Assets — provide security functions for the CUI environment, such as identity systems, logging and endpoint protection.
  • Contractor Risk Managed Assets — can, but are not intended to, process, store or transmit CUI because of policies and controls in place.
  • Specialized Assets — such as IoT, operational technology, government property and test equipment.
  • Out-of-Scope Assets — only when they cannot process, store or transmit CUI and are physically or logically separated from CUI assets.

An enclave works by making the boundary of CUI Assets small and the separation from everything else real.

What stays in scope

  • All 110 requirements apply inside the enclave.
  • The security tools and identity systems that protect the enclave are Security Protection Assets, so they are in scope too.
  • A cloud service that stores, processes or transmits CUI must meet FedRAMP Moderate or equivalent under DFARS 252.204-7012(b)(2)(ii)(D).

When an enclave fits, and when it doesn't

It fits when CUI touches a small team or a few workflows, such as one engineering group or one contract.

It doesn't when CUI is everywhere in the business. Then the friction of moving work in and out of the enclave can outweigh the scope savings, and protecting the whole environment may be simpler.

Questions to ask any enclave provider

  • Can I see your shared responsibility matrix, requirement by requirement?
  • What is your FedRAMP status, and what evidence supports it?
  • Which requirements do I inherit from you, which are shared, and which remain mine?

Frequently asked questions

Does a CMMC enclave reduce the number of requirements?

No. All 110 NIST SP 800-171 Rev. 2 requirements still apply inside the enclave. An enclave reduces how many assets are in scope, not which requirements apply.

Are the tools that protect the enclave in scope?

Yes. Security tools and identity systems that protect the enclave are Security Protection Assets under 32 CFR 170.19 and are in scope.

Does a cloud enclave need FedRAMP?

A cloud service that stores, processes or transmits CUI must meet FedRAMP Moderate or equivalent under DFARS 252.204-7012(b)(2)(ii)(D).

Further reading

Related Athena pages and authoritative external references.

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