Cyber DSC brief card: "The rule names no job title. It tests authority." — on who qualifies as CMMC Affirming Official under 32 CFR 170.22.

CMMC SPRS Affirmation: Who Can Sign and What the Affirming Official Is Certifying

Under 32 CFR § 170.22, the Affirming Official is defined by responsibility and authority, not by title. A CISO may qualify. So may an owner. A systems administrator who knows the environment best often does not — and neither does your MSP, consultant or C3PAO. What the rule actually requires, and what should sit in front of the signatory first.

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