Zscaler Zero Trust
by Zscaler
Covered
12
controls
Partial
3
controls
Gaps
3
controls
Overview
Zscaler Zero Trust by Zscaler is a network security solution that covers 12 NIST 800-171 controls (11% total coverage). It addresses key requirements in the network security domain for defense contractors pursuing CMMC compliance.
Controls Covered (12)
Partially Covered (3)
Implementation Notes
Deploy Zscaler Zero Trust with FIPS-validated configurations. Integrate with your SIEM for centralized audit logging. Review partial controls quarterly to identify supplementary tooling needs.
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Implementation Guidance for Zscaler Zero Trust
Configure Zscaler Zero Trust to satisfy NIST 800-171 requirements through these key control families: **Access Control (AC)**: Enable user and device verification through Zero Trust Network Access (ZTNA) policies. Configure conditional access rules based on device trust, location, and user identity. Set up application-specific access controls through Zscaler Private Access (ZPA) to enforce least privilege. **System and Communications Protection (SC)**: Implement SSL/TLS inspection for all traffic through Zscaler Internet Access (ZIA). Configure data loss prevention (DLP) policies to monitor CUI transmission. Enable cloud firewall rules and secure web gateway filtering. **Identification and Authentication (IA)**: Integrate with identity providers (Active Directory, Okta) for multi-factor authentication enforcement. Configure device certificates and posture assessment. **Assessment Evidence Generation**: Export user access logs, security policy violations, and threat detection reports from the Zscaler Admin Portal. Use the Analytics module to generate compliance dashboards showing policy enforcement metrics. Configure SIEM integration to centralize logs for audit trails. **Integration Strategy**: Deploy Zscaler Client Connector on all endpoints, integrate with existing identity management systems, and configure API connections to SIEM/SOAR platforms for centralized monitoring. **Common Misconfigurations**: Failing to enable SSL inspection for internal applications, insufficient DLP policy coverage for CUI data types, inadequate device posture policies allowing non-compliant devices access, and incomplete integration with identity providers leading to authentication bypass vulnerabilities.
Gap Analysis & Compensating Controls
The 3 uncovered NIST controls likely fall within **Configuration Management (CM)**, **System and Information Integrity (SI)**, and **Media Protection (MP)** families, representing critical gaps for defense contractors. **Configuration Management gaps** require dedicated tools like Rapid7 InsightVM or Tenable.io for vulnerability management and configuration compliance scanning. Implement automated patch management solutions and maintain configuration baselines through tools like Microsoft SCCM or Red Hat Satellite. **System and Information Integrity gaps** need endpoint detection and response (EDR) capabilities through CrowdStrike Falcon or Microsoft Defender for comprehensive malware protection and system monitoring beyond network-level controls. **Media Protection gaps** require data classification tools like Microsoft Purview or Varonis to handle CUI marking, encryption at rest, and secure media sanitization procedures. **Documentation Strategy**: List these gaps in your System Security Plan (SSP) with planned or implemented compensating controls. Create POA&M entries for each gap with specific remediation timelines and responsible parties. **Priority Ranking**: 1) Configuration Management (highest CMMC weight), 2) System Integrity (critical for threat detection), 3) Media Protection (important for CUI handling). Focus on configuration management gaps first as they typically represent the highest number of CMMC assessment objectives and are frequently cited in C3PAO findings for inadequate vulnerability management processes.
Compliance Cost Estimate
Zscaler Zero Trust licensing ranges from $7-15 per user per month depending on the service bundle (ZIA, ZPA, ZDX combinations). For a 100-user defense contractor, expect $8,400-18,000 annually in licensing costs. Implementation requires 40-80 hours of professional services ($150-250/hour) for initial configuration, policy development, and integration setup, totaling $6,000-20,000. Ongoing monitoring and maintenance costs include 0.25 FTE security analyst time ($20,000-30,000 annually) for policy management and incident response. Compared to competitors like Palo Alto Prisma SASE ($8-12/user/month) or Cisco SASE ($6-14/user/month), Zscaler offers competitive pricing with superior cloud-native architecture. Total three-year cost of ownership typically ranges $50,000-85,000 for small defense contractors (50-150 users), providing strong ROI through reduced on-premises infrastructure requirements and streamlined compliance reporting capabilities.
Compliance Cross-References
Zscaler Zero Trust directly supports **DFARS 252.204-7012** requirements for safeguarding covered defense information through network access controls, data loss prevention, and secure remote access capabilities. For **CMMC Level 2**, it addresses domains including Access Control (AC), System and Communications Protection (SC), and portions of Identification and Authentication (IA). Specifically satisfies assessment objectives: AC.L2-3.1.1 (authorized access), AC.L2-3.1.2 (transaction types), SC.L2-3.13.1 (boundary protection), and SC.L2-3.13.5 (communications protection). **FedRAMP alignment** includes AC-3 (Access Enforcement), SC-7 (Boundary Protection), and IA-2 (Identification and Authentication). **Additional Tool Requirements**: CMMC Level 2 compliance requires supplementing Zscaler with endpoint protection (CrowdStrike, SentinelOne), vulnerability management (Rapid7, Tenable), and configuration management tools (SCCM, Ansible) to achieve full coverage. The zero trust architecture provides strong foundation for multiple CMMC domains but cannot standalone satisfy all 110 security controls required for Level 2 certification.
Frequently Asked Questions
How many NIST 800-171 controls does Zscaler Zero Trust cover?
Zscaler Zero Trust covers 12 of 110 NIST 800-171 controls (11%), with 3 partially covered and 3 gaps.
Can Zscaler Zero Trust alone satisfy CMMC Level 2?
No single tool covers all 110 NIST 800-171 controls. Zscaler Zero Trust covers 11% and should be part of a layered security stack addressing the remaining controls.
What controls does Zscaler Zero Trust not cover?
Zscaler Zero Trust does not cover controls mp-3-8-1, ia-3-5-1, pe-3-10-1. These require supplementary solutions such as physical security controls, additional access management, or media protection tools.
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