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.
Zoom (Commercial)
by Zoom
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Video Conferencing
Overview
Zoom commercial is the standard business video conferencing platform. Unlike Zoom for Government, the commercial version is not FedRAMP authorized and must not be used for CUI discussions.
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)
Zoom (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 inventory all Zoom Commercial accounts and identify CUI exposure incidents for incident reporting under DFARS 252.204-7012.
- 2Security administrator must block Zoom Commercial domain access at firewall level and implement DNS filtering to prevent future installations.
- 3Contracts officer must review active contracts to identify CUI handling requirements and notify customers of platform change if meetings involved CUI discussion.
- 4ISSO must update System Security Plan Section 9 to remove Zoom Commercial from authorized external connections and system interfaces.
- 5Legal counsel must coordinate with Zoom Commercial to request data deletion and obtain written confirmation of account closure and data destruction.
- 6System administrator must deploy Zoom for Government or Teams GCC High with FIPS 140-2 encryption enabled and proper tenant isolation configured.
- 7ISSO must create POA&M entries documenting the compliance violation, remediation timeline, and ongoing monitoring requirements under NIST 800-171 control AU-6.
- 8Training coordinator must conduct mandatory user training on CUI identification and approved communication platforms within 30 days of platform migration.
- 9ISSO must update authorization boundary diagram to reflect removal of non-compliant external connection and addition of FedRAMP-authorized alternative.
- 10Compliance officer must notify DCMA or relevant assessment body of the compliance violation and provide written remediation evidence for CMMC assessment preparation.
NIST 800-171 Violations
Using Zoom (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 Zoom commercial FedRAMP authorized?
No. The commercial version of Zoom is not FedRAMP authorized. Only Zoom for Government holds FedRAMP Moderate authorization.
Can I discuss CUI on Zoom commercial?
No. Discussing CUI on commercial Zoom violates NIST 800-171 requirements. Use Zoom for Government or Teams GCC High instead.
What is a compliant alternative to Zoom commercial?
Zoom for Government (FedRAMP Moderate) is the direct compliant equivalent. Teams GCC High (FedRAMP High) offers higher authorization.
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