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Can Google Workspace Meet CMMC Level 2 Compliance for Handling CUI?

MLMatthew Locke (Co-Founder & CTO)
••15 min read
CMMCCybersecurityCompliance
IT administrator configuring Google Workspace security settings to meet CMMC Level 2 compliance requirements for Controlled Unclassified Information protection.

Can Google Workspace Meet CMMC Level 2 Compliance for Handling CUI?

Key Takeaways

  • Google Workspace can support CMMC Level 2 compliance for handling Controlled Unclassified Information (CUI), but requires strict configuration, boundary controls, and often additional encryption or third party tools.

  • Achieving compliance involves restricting Workspace services that handle CUI to FedRAMP Moderate authorized (or DoD-recognized equivalent) boundaries, optionally enabling client-side encryption, exporting audit logs securely, and using Assured Workloads to isolate CUI data.

  • For stringent Impact Level 5 (IL5) needs or export controlled data, Workspace may fall short; government cloud alternatives like GCC High might offer a simpler compliance path.

Introduction

In the defense contracting world, many small and medium sized businesses rely heavily on Google Workspace for communication and collaboration. A fundamental question arises: Can Google Workspace meet the Cybersecurity Maturity Model Certification (CMMC) Level 2 requirements for protecting Controlled Unclassified Information (CUI)?

The succinct answer is yes, but not without careful planning and extra work. Google Workspace offers a solid security foundation but must be tightly configured, with services restricted to compliant boundaries, and supplemented with additional controls such as client side encryption and audit log integrations. This article dives deep into what CMMC Level 2 demands, Google Workspace’s capabilities, gaps you must address, and practical ways to achieve compliance.

Understanding CMMC Level 2 Requirements

CMMC 2.0 Level 2 corresponds closely to the 110 security controls outlined in NIST SP 800-171 Revision 2. These controls impose requirements across numerous domains including access control, audit and accountability, configuration management, identification and authentication, incident response, and media protection.

"If your organization handles Covered Defense Information or CUI using any external cloud service, DFARS 252.204 7012 mandates that the Cloud Service Provider must meet security standards at least equivalent to FedRAMP Moderate, and support incident reporting and media safeguarding procedures."

In practical terms, contractors must ensure their cloud-based tools enforce technical and procedural safeguards to fulfill these controls, while maintaining compliance with reporting and preservation obligations as detailed in What Evidence is Needed for a CMMC Level 2 Assessment?.

What Google Workspace Brings to the Table

Google Workspace includes robust core security features that naturally align with many CMMC Level 2 objectives:

  • Encryption by default: Data stored and transmitted through Workspace services is encrypted. For increased assurance, Client Side Encryption is available, enabling encryption within the user’s browser where Google never holds the encryption keys.

  • Access and administrative controls: Multi-factor authentication, data loss prevention policies for Gmail and Drive, external sharing restrictions, and context aware access that attaches conditions to logins based on device trust.

  • Comprehensive audit logs: Administrators receive detailed logs available for export to Security Information and Event Management (SIEM) systems for deeper monitoring and long term retention.

  • Authorized Government Hosting: Workspace has received FedRAMP High authorization for key services, and DoD Impact Level 4 provisional authorization for the Enterprise Plus tier.

Google provides dedicated resources including a CMMC support page and a FedRAMP configuration guide to help organizations maintain compliant workspace environments.

Areas Requiring Extra Effort for Compliance

  • Control of Data Boundary and Residency: Define and enforce a compliant CUI boundary using Assured Workloads/Assured Controls (e.g., location and personnel controls) appropriate to your contract and risk posture. U.S.-only region/admin restrictions may be contract-specific but are not mandated by 32 CFR Part 170. Google’s solution involves activating Assured Workloads and Assured Controls to confine data inside U.S. regions and restrict administrative personnel access. Importantly, this is not the default state and needs deliberate setup.

  • Limiting Available Services: Not all Workspace features are in a FedRAMP-authorized boundary. To handle CUI, disable non-authorized services and leave only services that are FedRAMP Moderate authorized (or DoD-recognized equivalent) inside your defined boundary.

  • Audit Log Retention: Retain and protect audit records consistent with NIST SP 800-171 AU controls and any DFARS/contract requirements (e.g., preserve incident-related media per DFARS 252.204-7012). Export logs to a protected SIEM if native retention does not meet those needs.

  • End-to-End Confidentiality of CUI: Contracts or risk profiles may stipulate that the cloud provider cannot access your sensitive content. Leveraging client side encryption or an external encryption layer ensures that your data remains confidential beyond Google’s visibility.

  • Impact Level Scope Considerations: Workspace is authorized at Impact Level 4 (IL4). Google Cloud offers IL5 capabilities for selected services through Assured Workloads, but these may not extend fully to collaboration tools. Programs requiring IL5 may require specialized environments such as GCC High (/blog/microsoft-gcc-vs-gcc-high-small-defense-business).

Practical Compliance Approaches

Teams protecting CUI with Workspace often adopt these patterns:

  • Hardened Workspace Only Model: Maintain all collaboration in Google Workspace by enabling Assured Controls or Workloads, allowing only FedRAMP High approved services, activating client side encryption for key apps (Gmail, Drive), enforcing MFA and device posture policies, integrating logs with SIEM, and meticulously documenting these controls in the System Security Plan (SSP).

  • Split Environment Model: Use Workspace for non sensitive collaboration and Level 1 data, while isolating CUI in a separate, hardened enclave. This enclave can itself be a tightly controlled Google environment or an alternate platform that meets Level 2 criteria, aimed at reducing risk of data spills.

  • Third Party Control Layers: Enhance Workspace with additional tools for mail and file encryption, advanced monitoring, cloud access security broker (CASB) controls, and extended log retention. Each tool should clearly map to specific NIST SP 800-171 controls and be included in the SSP and Customer Responsibility Matrix.

When Does Workspace Fit Your Compliance Needs?

Use Case:
Only CMMC Level 1 (no CUI)
Workspace Suitability:
Feasible with baseline hardening of Workspace
Use Case:
Level 2 with limited/modest CUI
Workspace Suitability:
Viable if you implement controlled boundary, encryption, and logging
Use Case:
Strict IL5 requirements or export control
Workspace Suitability:
Likely not suitable; consider GCC High or other dedicated government clouds

Organizations that do not process CUI or only need Level 1 can leverage Workspace with standard hardening focused on access controls. For Level 2, collaboration is possible but demands investment in configurations, governance, and compensating controls. For strict Impact Level 5 or export-controlled workloads, Workspace’s coverage narrows and alternatives may better serve these needs.

Contextual Comparison: Google Workspace vs. Other Clouds

Microsoft’s official guidance underscores a crucial principle: CMMC certifies the contractor's implementation of controls—not the cloud platform itself. Any cloud provider used must be FedRAMP Moderate or higher. The contractor then applies the 110 controls through policies and technical safeguards.

Microsoft’s GCC and GCC High clouds are purpose built for government workloads, providing IL4 and IL5 support in a government-only personnel and data environment, which often reduces the number of compensating controls contractors must implement. However, these services come at a higher cost and may have functional differences compared to commercial offerings. In contrast, Google Workspace can be configured to meet these requirements, but achieving compliance typically entails more complex setup and boundary configurations.

Frequently Asked Questions

Can Google Workspace be used for CMMC Level 2 compliance?

Yes, it supports Level 2 compliance when limited to FedRAMP Moderate (or DoD-recognized equivalent) authorized services, used with Assured Workloads or Controls to isolate CUI, optionally using client-side encryption, and paired with secure audit logging and thorough SSP documentation.

Is Google Workspace FedRAMP Moderate or High authorized?

The in scope Workspace services are currently authorized at FedRAMP High level. Maintaining compliance requires disabling non authorized features and following Google's configuration best practices.

Does Google Workspace support DoD Impact Level 5?

Workspace itself documents Impact Level 4 authorization. Google Cloud offers IL5 for select services through Assured Workloads, but verify scope carefully before assuming IL5 coverage for collaboration tools. Many IL5 needs still favor specialized clouds like GCC High.

How should I explain CMMC compliance with cloud software like ERP to my customers?

Clarify that compliance applies to your company implementing controls over your IT environment, not the software itself. Explain how your ERP runs on FedRAMP Moderate or better infrastructure, how your security controls implement NIST SP 800-171, and how you meet incident reporting per DFARS 7012 regulations.

Can Google Workspace be configured as a CUI enclave?

Yes, by leveraging Assured Workloads to define the CUI boundary and apply location/personnel controls appropriate to your contract and risk posture (not a Part 170 mandate), plus Assured Controls to restrict sharing/features, Workspace can serve as a CUI enclave with proper monitoring and governance.

Conclusion

Google Workspace can indeed form a compliant foundation for securing CUI under CMMC Level 2, but the journey demands meticulous configuration, boundary management, encryption enhancements, and detailed audit logging. Organizations must weigh their compliance targets, data sensitivity, and governance capacity when choosing Workspace alone, a split approach, or third party add-ons.

Start by reviewing your data zoning, enable Workspace’s Assured Workloads and client side encryption, export and safeguard audit logs, and follow Google's official FedRAMP and CMMC configuration guides. For those with strict Impact Level 5 or export-controlled data needs, evaluate government clouds that might reduce your compliance burden.

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?.

By taking these measured steps, defense contractors can confidently leverage Google Workspace while meeting the rigorous demands of CMMC Level 2.

Ready to Assess Your Google Workspace Compliance Posture?

Perform a focused readiness check. Map your CUI data flows, configure tight service boundaries meeting FedRAMP Moderate (or DoD-equivalent) standards when CUI is handled, consider client-side encryption for mail and files where risk or contract terms warrant, route logs to a protected SIEM, and assess if a dedicated CUI enclave makes sense. Refer to Google’s official compliance guides, the DoD Level 2 Assessment Guide, DFARS 7012, and the latest NIST SP 800-171 Revision 2 (CMMC baseline) for detailed playbooks.

Your path to CMMC Level 2 compliance can start today:

To manage your CMMC compliance efforts more effectively, consider signing up for the CMMC Dashboard. Our platform helps you track your readiness, document controls, and prepare for assessments with ease.

References

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