Can Google Workspace Meet CMMC Level 2 Compliance for Handling CUI? (Updated for Final 48 CFR Rule)
"This article has been updated to align with the final CMMC Program Rule (32 CFR Part 170) and the CMMC Acquisition Rule (48 CFR / DFARS 252.204-7021), which became final on September 10, 2025, and take effect on November 10, 2025."
Key Takeaways
Google Workspace can support CMMC Level 2 compliance for Controlled Unclassified Information (CUI), but requires strict configuration, boundary management, and documentation.
Achieving compliance requires use of FedRAMP Moderate (or DoD-recognized equivalent) services, Assured Workloads, and client-side encryption.
Contractors must maintain a defined CUI boundary, export audit logs to a secure SIEM, and document every control in their System Security Plan (SSP).
For Impact Level 5 (IL5) or export-controlled data, Microsoft GCC High or equivalent government clouds may be a more straightforward option.
Introduction
Many defense contractors rely on Google Workspace for collaboration, but face uncertainty about whether it can meet CMMC Level 2 requirements for CUI. The short answer: Yes — with precise configurations and supplemental controls.
The final 48 CFR rule reinforces that compliance is the contractor’s responsibility, not the cloud provider’s. While Google Workspace offers strong security foundations, contractors must enforce boundary controls, logging, and encryption to align with DFARS 252.204‑7012 and NIST SP 800‑171 Rev 2.
Understanding CMMC Level 2 Requirements
CMMC Level 2 corresponds directly to the 110 controls in NIST SP 800‑171 Rev 2 and focuses on safeguarding CUI across domains such as:
Access control and authentication
Configuration management
Audit and accountability
Incident response and media protection
Under DFARS 252.204‑7012, any contractor handling CUI must ensure their Cloud Service Provider (CSP) meets FedRAMP Moderate or equivalent security standards and supports DoD incident reporting as detailed in What Evidence is Needed for a CMMC Level 2 Assessment?. The final CMMC 48 CFR rule now makes these obligations contractually enforceable.
What Google Workspace Offers for CMMC Compliance
Google Workspace provides strong built‑in controls aligned with many CMMC Level 2 requirements:
Encryption by Default: Data in transit and at rest is encrypted. Client‑Side Encryption (CSE) ensures Google never holds decryption keys.
Administrative Controls: MFA enforcement, data loss prevention (DLP) for Gmail and Drive, context‑aware access, and sharing restrictions.
Audit and Monitoring: Detailed audit logs can be exported to a Security Information and Event Management (SIEM) system for extended retention.
FedRAMP Authorization: Workspace Core Services are FedRAMP High authorized and operate within DoD Impact Level 4 (IL4) boundaries via Assured Workloads.
Documentation Support: Google provides a CMMC configuration guide and shared responsibility matrix to assist contractors in mapping controls.
These features provide a strong foundation, but achieving full compliance requires configuring Workspace with intentional, DoD‑aligned boundaries.
Areas That Require Additional Configuration or Controls
1. Boundary and Residency Management
Use Assured Workloads and Assured Controls to ensure CUI remains within U.S. regions and is only accessible by authorized U.S. personnel. This is not default behavior and must be explicitly configured.
2. Service Limitation
Disable any Workspace tools not covered by FedRAMP authorization. Only use services within the authorized boundary to handle CUI.
3. Audit Log Retention
CMMC requires logs to be retained and protected consistent with NIST SP 800‑171 AU controls. Export Workspace logs to a secure SIEM to meet retention and correlation requirements.
4. End‑to‑End Data Confidentiality
Use Client‑Side Encryption (CSE) for sensitive files and emails to ensure CUI remains inaccessible to Google and third parties.
5. Impact Level Limitations
Workspace maintains IL4 authorization. While IL5 coverage is available for some Google Cloud services through Assured Workloads, collaboration apps (e.g., Gmail, Drive, Docs) are not fully IL5. Programs requiring IL5 may need to migrate to Microsoft GCC Highor other DoD‑approved clouds.
Practical Compliance Models
Model 1: Hardened Workspace Enclave
Use Google Workspace exclusively for collaboration and enforce:
Assured Workloads/Controls for IL4 boundary
MFA and device posture enforcement
Client‑Side Encryption
Continuous log export to SIEM
Documentation of all controls in your SSP
Model 2: Split‑Environment Approach
Use Workspace for general collaboration but confine CUI activities to a dedicated, IL4‑compliant enclave (either Workspace or another FedRAMP Moderate+ environment). This minimizes CUI exposure and audit scope.
Model 3: Augmented Workspace with Third‑Party Tools
Integrate additional encryption, CASB, or DLP solutions to strengthen boundary controls and extend compliance functionality.
Comparison: Google Workspace vs. GCC High
| Feature | Google Workspace (Assured Workloads) | Microsoft GCC High |
|---|---|---|
| Feature: FedRAMP Authorization | Google Workspace (Assured Workloads): High | Microsoft GCC High: High |
| Feature: DoD Impact Level | Google Workspace (Assured Workloads): IL4 | Microsoft GCC High: IL5 |
| Feature: Client‑Side Encryption | Google Workspace (Assured Workloads): Yes | Microsoft GCC High: Yes |
| Feature: Admin Personnel | Google Workspace (Assured Workloads): U.S.‑based (with configuration) | Microsoft GCC High: U.S.‑only (default) |
| Feature: CUI Handling | Google Workspace (Assured Workloads): Viable with strict boundary | Microsoft GCC High: Native IL5 enclave |
| Feature: Best Fit For | Google Workspace (Assured Workloads): SMBs needing flexibility | Microsoft GCC High: Contractors handling export‑controlled data |
Conclusion
Google Workspace can meet CMMC Level 2 compliance requirements when configured and governed correctly under the final 48 CFR rule. However, compliance is not automatic, it depends on how contractors implement boundaries, logging, encryption, and SSP documentation.
For organizations handling FCI or limited CUI, Workspace offers a viable solution. For contracts requiring IL5 or export‑controlled data, GCC High or equivalent environments remain the safer choice.
To stay audit-ready through ongoing monitoring and organizational changes, leverage insights from the CMMC Assessment Process & Maintaining Certification and understand when re-certification is necessary as detailed in Do I Need to Re-Certify Every Time I Change My Network?.
FAQs (Frequently Asked Questions)
Frequently Asked Questions
Is Google Workspace officially approved for CMMC Level 2 use?
Yes — if configured with Assured Workloads, restricted to FedRAMP‑authorized services, and supplemented by required CMMC technical and procedural controls.
What version of FedRAMP does Workspace comply with?
Workspace Core Services are FedRAMP High authorized. However, not all add‑on tools or features fall under that boundary.
Can Workspace achieve IL5 equivalence?
Partially. IL5 support exists for some Google Cloud services under Assured Workloads, but not for Workspace collaboration tools. IL5 or export‑controlled workloads typically require GCC High.
What happens under the new 48 CFR rule if my cloud environment isn’t configured properly?
Misconfigured boundaries or non‑authorized services could lead to loss of certification or contract ineligibility once the rule is enforced.
How should contractors document compliance in Workspace?
Contractors must maintain a detailed System Security Plan (SSP) and Customer Responsibility Matrix, showing how each NIST 800‑171 control is implemented, including boundary configuration, encryption settings, and audit procedures.
Next Steps:
Perform a readiness review using Google’s CMMC Configuration Guide, confirm FedRAMP service scopes, and document every configuration step in your SSP. For structured compliance management, the CMMC Dashboard helps track controls, monitor boundaries, and prepare for third‑party assessments.