GCC High Vs GCC for Protecting CUI with CMMC

Choosing Between GCC and GCC High for CUI Compliance in 2025

For government contractors and organizations handling Controlled Unclassified Information (CUI), choosing the right Microsoft 365 environment is critical. Whether you’re working under CMMC 2.0, DFARS 252.204-7012, or ITAR, the decision between GCC and GCC High can impact compliance, security, and future contract opportunities.

This guide breaks down the latest updates and helps you determine which cloud environment aligns with your specific compliance needs.

Microsoft 365 Cloud Environments: What's the Difference?

Microsoft provides three cloud options tailored to different security and compliance needs:

• Microsoft 365 Commercial – Ideal for businesses that don’t handle government data. While feature-rich, it lacks the security controls needed for CUI and other federal requirements.
• Microsoft 365 GCC (Government Community Cloud) – Built for government agencies and contractors, this cloud environment meets FedRAMP Moderate but may not be sufficient for handling CUI requiring data sovereignty.
• Microsoft 365 GCC High – Designed for defense contractors and organizations managing highly sensitive data, including ITAR-controlled information. This environment meets FedRAMP High, DFARS 7012, and ITAR and restricts access to U.S. government-vetted users only.

Does Microsoft 365 Commercial Support FCI Protection?

Federal Contract Information (FCI) refers to non-public data generated under a government contract. It must be protected under FAR 52.204-21, but it does not require the same high-level security as CUI.

If your organization only handles FCI, you can store it in Microsoft 365 Commercial without needing GCC or GCC High. However, if your business manages both FCI and CUI, stricter security controls may apply, requiring a move to GCC or GCC High depending on your contract.

Protecting CUI: When is GCC High Required?

CUI includes sensitive but unclassified data that must be protected according to federal regulations. Choosing between GCC and GCC High depends on the type of CUI you handle.

Unspecified CUI

If your contracts involve CUI without strict dissemination controls, you may be able to store it in GCC as long as data sovereignty is not required. This is often the case for organizations managing CUI that falls under FedRAMP Moderate requirements.

However, if your future contracts could require stricter security controls, choosing GCC High from the start may help avoid costly migrations later.

Specified CUI and ITAR-Regulated Data

Some CUI categories have strict handling requirements due to their national security impact. This includes data regulated under:

• Export Control, Defense, and Nuclear CUI
• ITAR (International Traffic in Arms Regulations)
• CUI with NOFORN or REL TO USA dissemination controls

If your organization works with any of the above, GCC High or Azure Government is required to ensure compliance.

How to Choose Between GCC and GCC High

The decision ultimately depends on the type of CUI you handle and your contractual obligations.

GCC is sufficient for:

• CUI without dissemination restrictions
• Data that does not require U.S.-only data residency
• Organizations that only need FedRAMP Moderate compliance

GCC High is required for:

• ITAR-regulated data
• CUI with NOFORN or REL TO USA restrictions
• Export-controlled technical information
• Contracts that require FedRAMP High or DFARS 7012 compliance

If you’re unsure whether GCC meets your needs or if GCC High is required, reviewing your contract language or consulting compliance experts can help ensure you’re in the right environment before signing new agreements.

Final Thoughts: Staying Compliant in 2025

As CMMC 2.0 enforcement ramps up, defense contractors must stay ahead of compliance changes to remain eligible for DoD contracts. Microsoft’s GCC and GCC High environments provide different levels of security but choosing the wrong one can create costly compliance issues down the line.

For organizations looking to proactively manage security and compliance, consider AgileDefend with AgileThrive, our security and compliance service bundle designed to get you secure and keep you ahead of evolving regulations.

Need help evaluating your cloud environment for compliance? Consult with Agile IT to ensure your CUI and ITAR data are fully protected under the latest federal regulations.