Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Zoho CRM
by Zoho
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
CRM
Overview
Zoho CRM is a commercial customer relationship management platform offering sales automation and analytics. It lacks FedRAMP authorization and cannot be used for CUI workloads.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Zoho CRM 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: Conduct immediate CUI data audit of all Zoho CRM records, opportunities, and attachments (Week 1-2)
- 2Sysadmin: Export all non-CUI data using Zoho's data export functionality and secure transfer protocols (Week 3)
- 3Contracts: Identify FedRAMP-authorized CRM alternatives (Dynamics 365 GCC High, Salesforce Government Cloud) and initiate procurement (Week 2-3)
- 4ISSO: Update authorization boundary diagrams to remove Zoho CRM from all CUI processing flows (Week 4)
- 5Sysadmin: Configure replacement CRM platform with CMMC Level 2 security controls and integration testing (Week 5-8)
- 6Training Manager: Develop CUI awareness training specific to CRM usage and sales team workflows (Week 6-7)
- 7ISSO: Update System Security Plan, incident response procedures, and data handling documentation (Week 9)
- 8Contracts: Terminate Zoho CRM subscription and document compliance remediation for DCMA/DIBCAC records (Week 10)
NIST 800-171 Violations
Using Zoho CRM 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 Zoho CRM FedRAMP authorized?
No. Zoho CRM does not hold a FedRAMP authorization and is not listed on the FedRAMP Marketplace.
Can I use Zoho CRM with CUI?
No. Zoho CRM is not authorized for CUI. Defense contractors must use a FedRAMP authorized CRM such as Salesforce Government Cloud or Dynamics 365 GCC High.
What is a compliant alternative to Zoho CRM?
Salesforce Government Cloud (FedRAMP High) and Microsoft Dynamics 365 GCC High (FedRAMP High) are compliant CRM alternatives approved for CUI.
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