What does H33-74 do for CMMC 2.0?

H33-74 produces each access event, configuration change, incident classification, and access-revocation decision as a post-quantum-signed proof at the moment it occurs. It produces evidence that supports CMMC 2.0 practices; it does not by itself make a contractor certified.

Is H33-74 changed for CMMC 2.0?

No. H33-74 is the same portable post-quantum evidence primitive here as everywhere else. Only the application context differs: proofs are mapped to CMMC control families such as AC, AU, CM, IR, IA, SI, SC, and MA at Levels 1 through 3.

Does the evidence survive MSP, SIEM, or cloud changes?

Yes. Provider changes do not weaken the evidence. The C3PAO assesses controls by verifying the proofs directly, so changing MSP providers, replacing SIEM tools, or migrating clouds does not create evidence gaps for the next assessment or DIBCAC review.

How is audit information protected under AU.L2-3.3.8?

Protection of audit information is structural via post-quantum signatures rather than contractual via log-protection controls. Each auditable event is an independently verifiable cryptographic object signed with three independent post-quantum signature families.

H33-74 for CMMC 2.0 — Chain-Portable DoD Evidence

Cybersecurity Maturity Model Certification 2.0 (United States Department of Defense, Defense Industrial Base contractors and subcontractors) places obligations on organizations to demonstrate that operational controls were in place, that automated decisions were governed, and that an audit trail exists for regulatory inquiry. Most existing audit-log architectures meet the letter of the requirement but produce evidence tied to the operator's current systems. If those systems change or fail, the evidence weakens.

H33-74 produces audit evidence that survives the system that produced it. The proof is cryptographically verifiable independent of the operator. The PQ signatures survive the quantum transition. The chain anchors survive any single chain's deprecation.

What CMMC 2.0 requires

CMMC 2.0 applies to organizations in the Defense Industrial Base (DIB) that handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) under DoD contracts. Three certification levels: Level 1 Foundational (17 practices aligned to FAR 52.204-21, annual self-assessment) for FCI; Level 2 Advanced (110 practices aligned to NIST SP 800-171, triennial C3PAO assessment) for CUI; Level 3 Expert (110+ practices plus a subset of NIST SP 800-172, triennial DIBCAC assessment) for high-priority CUI. The DoD CMMC Final Rule (CFR 48 Part 204) became effective in 2025 and contracts are incorporating CMMC requirements as a condition of award. Contractors at every tier of the supply chain are in scope.

Why H33-74 fits

CMMC audit obligations require evidence that controls have been in place continuously across the contract performance period, often years after specific access events, configuration changes, and incidents occurred. Contractors routinely change MSP providers, replace SIEM tools, migrate to different clouds, and consolidate after M&A — and each change creates evidence gaps that complicate the next C3PAO assessment or DIBCAC review. H33-74 produces each access event, each configuration change, each incident classification, and each access-revocation decision as a cryptographically verifiable post-quantum proof at the moment it occurs. The C3PAO assesses controls by verifying the proofs directly; provider changes do not weaken the evidence.

Control mapping

AC.L2-3.1.* — Access control

Each access decision (grant, modify, revoke), each privileged action, and each session termination emits a proof recording the subject, object, action, and policy basis. Joint Surveillance Audit verifies AC evidence directly.

AU.L2-3.3.* — Audit and accountability

Each auditable event emits a proof. The audit log becomes a sequence of independently verifiable cryptographic objects. AU.L2-3.3.8 protection of audit information is structural via PQ signatures rather than contractual via log protection controls.

CM.L2-3.4.* — Configuration management

Each configuration change, each baseline review, each approved deviation emits a proof recording the requester, approver, change content, and rollback path. Baseline drift detection produces verifiable evidence.

IR.L2-3.6.* — Incident response

Each incident detection, classification, containment decision, and notification emits a proof. The 72-hour DoD incident reporting under DFARS 252.204-7012 is backed by cryptographically anchored detection and classification events.

IA.L2-3.5.* — Identification and authentication

Each MFA enrollment, credential issuance, and authentication exception emits a proof. Privileged authentication events produce a verifiable audit trail independent of the IdP vendor.

SI.L2-3.14.* — System and information integrity

Each malware detection, each flaw remediation, and each security relevant change emits a proof. SI evidence survives the EDR or SIEM that produced it.

SC.L2-3.13.* — System and communications protection

Each cryptographic key rotation, each session boundary enforcement decision, and each cross-domain transfer decision emits a proof.

MA.L2-3.7.* — Maintenance

Each maintenance action including remote maintenance approval and offsite media handling emits a proof recording the approver, the maintenance party, and the disposition.

Level 3 — Advanced threat (subset of SP 800-172)

Adversarial actions monitoring, threat hunting outcomes, and supply-chain risk decisions emit proofs that support the DIBCAC assessment.

What this changes for the audit team

Each control's evidence is a cryptographic object the auditor verifies directly, not a log entry the auditor trusts because the operator says so.
The audit horizon extends beyond the operator's current systems, vendors, or chain choices.
Regulator inquiry years after a decision can be answered with the original PQ-signed proof rather than reconstructed from operator memory.
Independent third-party verification works without the operator's infrastructure being available.

The CMMC 2.0 audit trail becomes chain-portable evidence. Each control's record outlives the system that produced it, the vendor that hosts it, and the chains it was anchored to.

None of this redefines the primitive: H33-74 produces/anchors the same portable 74-byte post-quantum receipt for CMMC 2.0 that it does for any other use, and it produces evidence that supports CMMC practices rather than making a contractor certified on its own. How anyone checks a receipt — recompute the commitment, verify the signatures, confirm the anchor, with H33 not in the loop — is described under Verification.

The chain-portable evidence model

Read the architectural concept underneath every H33-74 regulatory deployment.

Chain Portability Why Chain Migration Shouldn't Exist

H33-74 for CMMC 2.0

What CMMC 2.0 requires

Why H33-74 fits

Control mapping

What this changes for the audit team

The chain-portable evidence model

Related regulatory crosswalks