Microsoft 365 (Commercial)
by Microsoft
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Overview
Commercial Microsoft 365 is the standard version used by most businesses worldwide. It is explicitly non-compliant for CUI handling — data may reside outside the US, support is provided by non-US persons, and it holds no FedRAMP authorization. Thousands of small defense contractors still use commercial M365 for email, SharePoint, and Teams, creating their largest compliance gap.
CUI Risk Assessment
Commercial M365 is explicitly non-compliant for CUI. No longer recognized as FedRAMP equivalent under the 48 CFR final rule. Data may reside outside the US. Any CUI in M365 Commercial prevents CMMC certification.
NIST 800-171 Violations
Using Microsoft 365 (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
FedRAMP Compliant Alternatives
Frequently Asked Questions
Can I use regular Microsoft 365 with CUI?
No. Commercial Microsoft 365 is not FedRAMP authorized and is explicitly non-compliant for CUI. You need Microsoft 365 GCC High for DoD CUI workloads.
Is Microsoft 365 commercial FedRAMP equivalent?
No. The 48 CFR final rule eliminated FedRAMP equivalency claims for commercial cloud products. Commercial M365 is not recognized as FedRAMP equivalent.
What happens if I have CUI in commercial M365?
You are non-compliant with DFARS 252.204-7012 and will fail a CMMC assessment. You must migrate CUI workloads to GCC High or an alternative like PreVeil.
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