Not CUI Compliant
4 NIST 800-171 gaps detected. Commercial Intune is not FedRAMP authorized. Device management data may be processed outside the US. Cannot be used to manage devices accessing CUI.
Microsoft Intune (Commercial)
by Microsoft
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Endpoint Management
Overview
Commercial Microsoft Intune shares global infrastructure and is not FedRAMP authorized. Many contractors use commercial Intune alongside commercial M365 without understanding that device management for CUI environments requires GCC High.
CUI Risk Assessment
Commercial Intune is not FedRAMP authorized. Device management data may be processed outside the US. Cannot be used to manage devices accessing CUI.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Microsoft Intune (Commercial) has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO must immediately update the POA&M to document Intune Commercial as a finding under NIST 800-171 controls 3.1.1, 3.4.1, 3.4.2, and 3.13.8 requiring remediation within 180 days.
- 2Contracts officer must review all active DoD contracts to identify CUI handling requirements and notify customers of planned migration to compliant MDM solution.
- 3Sysadmin must inventory all devices currently enrolled in Intune Commercial and classify which devices access CUI versus non-CUI systems.
- 4ISSO must procure Microsoft Intune for Government (GCC High) licenses and establish new tenant within FedRAMP boundary.
- 5Sysadmin must export all device compliance policies, application configurations, and conditional access rules from commercial tenant for migration planning.
- 6ISSO must update System Security Plan Section 10 (Authorization Boundary) to remove Intune Commercial and add planned GCC High implementation.
- 7Sysadmin must configure device compliance policies in GCC High tenant that meet NIST 800-171 requirements for access control and system protection.
- 8IT staff must conduct phased device re-enrollment starting with non-production devices, validating compliance policy enforcement before migrating production CUI devices.
- 9ISSO must update authorization boundary diagrams to reflect GCC High MDM integration and remove commercial Intune connections.
- 10Compliance officer must conduct final validation that all CUI-accessing devices are managed exclusively through FedRAMP-authorized GCC High tenant before closing POA&M entries.
NIST 800-171 Violations
Using Microsoft Intune (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Related Compliance Assessments
Frequently Asked Questions
Is commercial Intune sufficient for managing devices with CUI access?
No. Commercial Intune is not FedRAMP authorized. Intune in GCC High is required for managing devices that access, process, or store CUI.
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