Best CMMC enclave options for small contractors
Published 2026-10-22
An enclave is a small box for your CUI. Instead of bringing every laptop, printer and file share into your assessment, you put the controlled drawings and email in one separated system and draw the boundary around that. The rule allows it: under 32 CFR 170.19, assets that are physically or logically separated from CUI assets are out of scope. The box still has to meet all 110 requirements of NIST SP 800-171 Rev 2, and the separation itself is a control you must prove: CUI flows only where you allow it AC.L2-3.1.3, and the boundary is monitored and protected SC.L2-3.13.1.
We read six ways to build one, from an encrypted file app to a single hardened laptop, against what the rule asks of each. Not sure what counts as CUI in your shop yet? Run the is it CUI? check first, then mark the boundary with the CMMC scoping worksheet.
- In force today
- DFARS 252.204-7012 still applies: NIST SP 800-171 Rev 2 on systems that hold covered defense information, cyber incidents reported to DoD within 72 hours, and FedRAMP Moderate or equivalent for any cloud that holds it. DFARS 252.204-7012(b)(2), (c)
- Contracts may require CMMC Level 1 (Self) or Level 2 (Self): your own assessment, scored and entered in SPRS, with a senior official's affirmation. Class Deviation 2026-O0025 Rev 3; 32 CFR 170.15, 170.16
- The CMMC rule itself, 32 CFR Part 170, is unchanged since it took effect on 2024-12-16. eCFR, 32 CFR Part 170
- Suspended
- Phase 2, due in November 2026, is suspended for every contractor, whatever its size: contracts are not adding the third-party Level 2 (C3PAO) or Level 3 (DIBCAC) requirements. DoW CIO memo of 2026-07-13, applied by Class Deviation 2026-O0025 Rev 3
- Existing contracts that carry CMMC requirements have them removed at the next option period or the next scheduled administrative modification. Class Deviation 2026-O0025 Rev 3
- Not yet known
- The outcome of the CMMC Reform Task Force review is not confirmed as of 2026-10-23: no report or rule change has been published. Federal Register search, 2026-10-23
- DoD's 2026 Regulatory Plan lists an interim final rule amending 32 CFR Part 170 (RIN 0790-AM01) to set a deadline and transition from NIST SP 800-171 Rev 2 to Rev 3. It was timetabled for July 2026 and has not been published as of 2026-10-23. 91 FR 52824
- Class Deviation 2026-O0025, Revision 3 (DFARS part 240), read 2026-10-23
- DFARS 252.204-7012, -7019, -7020, -7021 (acquisition.gov), read 2026-10-23
- 32 CFR Part 170 (eCFR), read 2026-10-23
- Federal Register 2026-16603, 2026 Regulatory Plan (RIN 0790-AM01), read 2026-10-23
- Federal Register: CMMC documents, read 2026-10-23
PreVeil
It keeps CUI in a small encrypted box beside the email you already use, states 7012 incident support, and lets outside companies join for free. Ask for the equivalency evidence before you sign.
Read the PreVeil notesTotem HRDN-IT
When one person handles the CUI, a single hardened laptop on its own router takes the cloud question off the table and keeps the boundary the size of a desk.
Read the Totem HRDN-IT notesAriento Enclave One
Licensing, documents, help desk and monitoring from one MSP, on Microsoft's government cloud, for a team that would rather not run the boundary itself.
Read the Ariento Enclave One notes
An enclave or the whole company?
Scope is what you pay for. Every asset inside the boundary goes in the asset inventory, the system security plan and the network diagram, and is assessed. In a small machine shop that is most of the building: office laptops, the file share with drawings, everyone's email, often the machines on the floor. An enclave moves most of that list outside the line. Size it after you know what you hold: the FCI vs CUI comparison sorts the documents first.
| Asset | Whole company in scope | With an enclave |
|---|---|---|
| Office laptops that never open CUI | In the inventory, the SSP and the network diagram, as CUI Assets or Contractor Risk Managed Assets | Out of scope, if they cannot reach the CUI or only show a remote desktop |
| CNC controllers, CMMs and test equipment | Specialized Assets: listed in the inventory and SSP, managed by your own policy | Out of scope only if no CUI drawing or program ever reaches them |
| Email for the whole company | Any mailbox that receives CUI is a CUI Asset, and the mail cloud needs FedRAMP Moderate or equivalent | Only the enclave's mail holds CUI; the rest stays where it is |
| Firewall, identity system, log and backup tools | Security Protection Assets, assessed for what they provide | Still Security Protection Assets for the enclave: this part does not shrink |
The last row is the one sellers skip. The systems that protect the enclave stay in scope however small the box gets, and the CNC row is where shops get caught: if the programmer opens a customer's drawing on the shop-floor PC, the enclave did not hold.
Leans to an enclave
- A few people handle CUI; most never see it
- CUI arrives as drawings, specs and email
- Defense work is a slice of your revenue
Leans to the whole company
- Drawings travel to every machine on the floor
- Most staff touch CUI every week
- The box would push people to copy CUI out of it
Five ways to build one
Every enclave on this page is one of five shapes. The shape decides what stays outside the line and where the boundary is easiest to break, which matters more than any single feature.
| Shape | Where the CUI lives | What can stay outside | Where it breaks |
|---|---|---|---|
| Encrypted file and email app | Inside the app, encrypted, in the vendor's cloud | Your normal email, laptops and file share, as long as CUI only lives in the app | A drawing saved to the desktop or attached to a normal email puts that PC or mailbox back in scope. |
| Government cloud tenant | A second Microsoft 365 tenant used only by the people who handle CUI | The commercial tenant for everyone else | Files in GCC High can be shared only with other GCC High organizations, so outside partners need another route. |
| Virtual desktop | In the cloud desktop; the PC only shows the screen | The PC itself, if it passes keyboard, video and mouse and nothing else | Copy, paste, download or print to the PC and the PC is in scope again. |
| Managed enclave from an MSP | The MSP's environment (Enclave One runs on Microsoft GCC or GCC High) | Your own network, for the people who stay outside | The MSP is an External Service Provider: it goes in your SSP with its responsibility matrix. |
| One hardened PC on its own router | On that laptop and its encrypted backup drive | Everything else in the building | Physical controls now matter: who can reach the laptop, where it sits, where it prints. |
Six enclaves against the rule
Rows inside the boundary are what the rule asks of the enclave and of any cloud that holds your CUI. Rows outside it are how the box fits the way a shop works. Every word in the table was read on the vendor's own pages or the FedRAMP Marketplace on 2026-10-22.
| What the rule asks | PreVeil | Kiteworks | Microsoft 365 GCC High | Azure Virtual Desktop in Azure Government | Ariento Enclave One | Totem HRDN-IT |
|---|---|---|---|---|---|---|
| Inside the boundary | ||||||
| FedRAMP Moderate or equivalent for any cloud that holds the CUIDFARS 252.204-7012(b)(2)(ii)(D) | Vendor states equivalency | Certified (Moderate) | Certified (High) | Certified (High) | Inherited from platform | No cloud |
| Covers the 110 requirements inside the enclave (the vendor's own mapping)32 CFR 170.14(c)(3); NIST SP 800-171 Rev 2 | Part stated | Part stated | Not stated | Part stated | Vendor states certified | Part stated |
| Shared responsibility matrix you can put in your SSP32 CFR 170.19(c)(2)(ii) | On request | Not stated | Partial | Stated | Partial | Not stated |
| US-persons support path, or another route for ITAR technical data22 CFR 120.54(a)(5); 22 CFR 120–130 | Carve-out stated | US citizens stated | ITAR terms | Stated | US personnel stated | Not stated |
| Backs DFARS 7012 incident reporting: 72 hours, images kept 90 daysDFARS 252.204-7012(c), (e) | 7012 (c)–(g) stated | Not stated | In DFARS scope list | Stated | IR stated, 72 h not named | IR stated, 72 h not named |
| Outside the boundary | ||||||
| Runs beside the systems you keep for everything else | Stated | Not stated | Partial | Stated | Stated | Partial |
| Sharing CUI with customers and suppliers outside the company | Stated | Stated | Partial | Not stated | Stated | Not stated |
| Someone runs it for you day to day | Partial | Not stated | Not stated | Not stated | Stated | Stated |
What the words mean
- MeetsCarve-out stated7012 (c)–(g) statedStatedCertified (Moderate)US citizens statedCertified (High)ITAR termsNo cloud
- The vendor's own documentation, or the official register, says so. Read on the date shown.
- PartialVendor states equivalencyPart statedOn requestPartialIn DFARS scope listInherited from platformVendor states certifiedUS personnel statedIR stated, 72 h not named
- Covers part of the requirement, or the vendor claims it and the official register does not show it.
- Check with vendorNot stated
- Not stated in what we read. Ask the vendor in writing before you rely on it.
The cloud rule every enclave answers to
Five of the six options keep your CUI in someone else's cloud, and that is not a CMMC rule first. It is DFARS 252.204-7012, which applies today whatever happens to CMMC Phase 2:
There are two ways a provider passes. An authorization shows on the FedRAMP Marketplace, and you can read it yourself. Equivalency does not show there: the DoD CIO memo of 2023-12-21 says an equivalent offering must reach 100 percent of the FedRAMP Moderate baseline, assessed by a FedRAMP-recognized 3PAO, and give you the body of evidence. A vendor page that says "FedRAMP equivalent" is the start of that conversation, not the end of it. The full test is in FedRAMP Moderate equivalency explained.
Read the Marketplace even for the big names, on the live product page. On 2026-10-22 it listed Azure Government and Microsoft 365 GCC High as FedRAMP Certified at High (Class D) and Kiteworks Federal Cloud at Moderate (Class C); the Marketplace now says "Certified" where the rule says "authorized". Older copies of the Marketplace data still showed GCC High as In Process, so cite the page, not a download. The shortlist of tenant alternatives is in GCC High alternatives.
The VDI rule that makes a desktop enclave work
The virtual desktop shapes rest on one sentence in the scoping table. It is what lets the PC on the desk stay outside the boundary while the work happens inside it:
The key word is configured. A desktop that lets CUI reach the PC breaks the sentence, and the PC is back in scope. Ask whoever builds the desktop to show these four settings turned off, and keep the evidence for your SSP.
| If the desktop allows | Why the PC comes back in scope |
|---|---|
| Clipboard copy from the desktop to the PC | CUI text leaves the desktop and sits on the PC. |
| Mapped local drives or file download | A drawing can be saved to the PC's disk: storage, not just a screen. |
| Printing to a printer attached to the PC | CUI is transmitted to the PC and out of it on paper. |
| USB device pass-through | A thumb drive on the PC becomes a path into and out of the desktop. |
What the enclave does not hand off
A good enclave shrinks the work. It does not move the contract. The clauses bind your company, and the providers we read say so plainly: PreVeil's virtual desktop terms make the customer solely responsible for monitoring, incident response and regulatory reporting inside the desktop, apart from the reporting support they list, and Ariento's FAQ tells customers they must attest in SPRS once a year themselves.
| What the rule asks | Who does it |
|---|---|
| Report a cyber incident to DoD within 72 hours of discovery, through dibnet.dod.mil, with a medium assurance certificateDFARS 252.204-7012(c) | You. A provider's help is written into its contract, or it is not there. |
| Keep images of affected systems and monitoring data for at least 90 days from the reportDFARS 252.204-7012(e) | You, with the provider's part spelled out in writing. |
| Put the provider, its services and its responsibility matrix in your SSP32 CFR 170.19(c)(2)(ii) | You. Ask for the matrix before you sign, not at assessment time. |
| Score the enclave, enter the result in SPRS and affirm it32 CFR 170.22 | Your Affirming Official, every year, whoever runs the box. |
The 72-hour clock is the one to rehearse. Get the medium assurance certificate before you need it, and know who at the provider pulls logs at night. The clause itself is walked through in DFARS 252.204-7012 explained, and your score for the box can be checked with the SPRS score calculator. If you want a tool to hold the SSP and the score, see CMMC compliance software compared.
ITAR data takes one of two routes
If your drawings are ITAR technical data, the enclave has a second job. One route keeps the data where only US persons can reach it: GCC High, Azure Government, Kiteworks and Ariento each state US-citizen, screened US-person or US-only staff. The other route is the end-to-end encryption rule in 22 CFR 120.54: sending or storing unclassified technical data is not an export when it is encrypted end to end with FIPS 140-2 modules or their successors (or at least AES-128 strength), the means of decryption go to no third party, and it is not stored in a proscribed country. PreVeil relies on that rule rather than on US-only staff. Both routes are legitimate; which one your customer's contract or your export lawyer expects is the question to settle first. More in what ITAR compliance means for a shop and ITAR-compliant file sharing compared.
The options, one by one
PreVeil
What it is. End-to-end encrypted email and file sharing that sits beside your existing Microsoft 365, Exchange or Google mail. Only the people who touch CUI get it, and files are stored in AWS GovCloud. PreVeil states it supports 102 of the 110 NIST SP 800-171 requirements, meets the FedRAMP Moderate baseline by equivalency, and supports DFARS 7012 (c) through (g) incident reporting; it ships pre-filled SSP and policy documents and gives outside companies free accounts. It also offers a managed virtual desktop on AWS GovCloud, whose responsibility matrix is available on request.
Who it fits. A shop whose CUI arrives as drawings and email from the prime, with a handful of people who handle it and no wish to move everyone to a new tenant.
| What the rule asks | What we found |
|---|---|
| FedRAMP Moderate or equivalent for any cloud that holds the CUI | Vendor states equivalency |
| Covers the 110 requirements inside the enclave (the vendor's own mapping) | Part stated |
| Backs DFARS 7012 incident reporting: 72 hours, images kept 90 days | 7012 (c)–(g) stated |
Checked on preveil.com, 2026-10-22
Check with the vendor before you buy.
Kiteworks
What it is. One platform for secure email, file sharing, managed file transfer, SFTP and web forms, with one audit log across them. Its Federal Cloud runs single-tenant in AWS and holds a FedRAMP Moderate authorization; its Secure Gov Cloud is listed in the Marketplace as Agency Authorization In Process at High. Kiteworks states it supports 90% of Level 2 requirements and that its FedRAMP service is supported in the US by US citizens.
Who it fits. A shop that moves large CAD files and bulk transfers with primes and suppliers and wants a FedRAMP authorization it can point to in the Marketplace.
| What the rule asks | What we found |
|---|---|
| FedRAMP Moderate or equivalent for any cloud that holds the CUI | Certified (Moderate) |
| Covers the 110 requirements inside the enclave (the vendor's own mapping) | Part stated |
| US-persons support path, or another route for ITAR technical data | US citizens stated |
Checked on kiteworks.com, 2026-10-22
Check with the vendor before you buy.
Microsoft 365 GCC High
What it is. A separate Microsoft 365 environment for contractors holding DoD CUI or ITAR data, sold through volume licensing after an eligibility check. As an enclave, only the CUI users get GCC High accounts; everyone else stays on the commercial tenant. Staff with access to customer content pass US citizenship checks, files can be shared only with other GCC High organizations, and the FedRAMP Marketplace lists GCC High as FedRAMP Certified at High.
Who it fits. A shop that already lives in Outlook, Teams and SharePoint and has a Microsoft partner to set up and run a second tenant.
| What the rule asks | What we found |
|---|---|
| FedRAMP Moderate or equivalent for any cloud that holds the CUI | Certified (High) |
| US-persons support path, or another route for ITAR technical data | ITAR terms |
| Sharing CUI with customers and suppliers outside the company | Partial |
Checked on learn.microsoft.com, 2026-10-22
Check with the vendor before you buy.
Azure Virtual Desktop in Azure Government
What it is. Windows desktops that run in Azure Government and stream to the user's own PC. CUI stays in the cloud desktop; the PC only shows the screen. You or your IT provider build and run the desktops. Azure Government is FedRAMP Certified at High in the Marketplace, which names Windows Virtual Desktop among its services, limits access to screened US persons, has a 3PAO attestation for the cloud provider's side of DFARS 7012, and comes with a DFARS customer responsibility matrix.
Who it fits. A shop with an IT provider who knows Azure, where the CUI work needs Windows apps (CAD, CAM, ERP) rather than just email and files.
| What the rule asks | What we found |
|---|---|
| FedRAMP Moderate or equivalent for any cloud that holds the CUI | Certified (High) |
| Shared responsibility matrix you can put in your SSP | Stated |
| Backs DFARS 7012 incident reporting: 72 hours, images kept 90 days | Stated |
Checked on learn.microsoft.com, 2026-10-22
Ariento Enclave One
What it is. A managed enclave from an MSP: Microsoft 365 GCC or GCC High licensing, documentation, help desk and a 24/7 security operations center in one subscription. Ariento says the enclave is an already certified assessment scope, assessed quarterly by rotating C3PAOs, and states its staff are US personnel with no outsourcing. Customers still attest in SPRS once a year themselves.
Who it fits. A first-time DoD contractor, an SBIR awardee or a small team inside a bigger company that wants someone else to run the boundary.
| What the rule asks | What we found |
|---|---|
| Covers the 110 requirements inside the enclave (the vendor's own mapping) | Vendor states certified |
| US-persons support path, or another route for ITAR technical data | US personnel stated |
| Someone runs it for you day to day | Stated |
Checked on ariento.com, 2026-10-22
Check with the vendor before you buy.
Totem HRDN-IT
What it is. An on-premise enclave of one hardened Windows 11 laptop, a hardened router and a FIPS-validated backup drive, shipped with a customized SSP and POA&M. Local apps replace Microsoft 365, so no cloud holds the CUI unless you add one. Totem says the build meets most technical requirements of NIST SP 800-171 and lists the rest on the POA&M; its Managed tier adds monitoring and incident response assistance.
Who it fits. A one- or two-person shop, an SBIR awardee or a home-office contractor whose CUI work fits on one machine.
| What the rule asks | What we found |
|---|---|
| FedRAMP Moderate or equivalent for any cloud that holds the CUI | No cloud |
| Covers the 110 requirements inside the enclave (the vendor's own mapping) | Part stated |
| Someone runs it for you day to day | Stated |
Checked on totem.tech, 2026-10-22
Check with the vendor before you buy.
How we read the vendors
Questions small shops ask
Is an enclave allowed under CMMC?
Yes. 32 CFR 170.19 treats assets that are physically or logically separated from CUI assets as out of scope, and asks you to be ready to justify why each one cannot process, store or transmit CUI. The enclave is that separation, written into your inventory, network diagram and SSP.
Do I still need an enclave while Phase 2 is suspended?
The suspension pauses third-party certification; it does not lift DFARS 252.204-7012. NIST SP 800-171 Rev 2 still applies to every system that holds covered defense information, and contracts may still ask for a Level 2 self-assessment. A smaller boundary makes both cheaper, so the reason for an enclave is unchanged. What still applies today.
Does a pre-certified MSP enclave mean my company is certified?
Read the words carefully. Ariento describes Enclave One as an already certified assessment scope that customers join, assessed quarterly by rotating C3PAOs, and still asks each customer to attest in SPRS every year. A certificate belongs to an assessment of a scope; confirm in writing which scope your CAGE code is tied to and what your own SSP has to say.
Can CNC machines stay outside the enclave?
Only if no CUI reaches them. A CNC controller that runs a program made from a controlled drawing is handling CUI, and the rule names operational technology and test equipment as Specialized Assets that go in your inventory and SSP. Whether a program made from a controlled drawing is itself CUI is a call to settle with your customer and write down. The is it CUI? check helps with that call.
Who should build the enclave for a ten-person shop?
If you have no IT person, a managed option or an MSP who has built enclaves before. Ask any MSP for its responsibility matrix: if it holds your security data it is in your assessment scope as well. The CMMC MSP comparison lists what to ask.