Why CHIPS Act Manufacturers Can't Rely on CMMC Pen Testing Alone

Semiconductor manufacturers pursuing CHIPS Act funding face a compliance environment that most cybersecurity frameworks were not designed to handle simultaneously. CMMC 2.0 governs their obligations as defense supply chain participants. CHIPS Act cybersecurity conditions govern their obligations as recipients of federal manufacturing investment. These are not the same requirements, and the overlap between them is not as clean as either framework document suggests.

How the Two Frameworks Create a Dual Obligation

CMMC 2.0 is a supply chain security framework. Its requirements flow from the DoD's need to protect controlled unclassified information across the defense industrial base. For a semiconductor manufacturer supplying components or designs to defense programs, CMMC Level 2 or Level 3 requirements apply to the systems that handle that CUI.

CHIPS Act cybersecurity conditions are tied to funding eligibility and ongoing compliance for facilities receiving grants or loans under the program. They focus on protecting the advanced manufacturing capabilities and intellectual property that the federal investment is funding. The threat model is different: less about protecting DoD information and more about protecting domestic semiconductor technology from foreign adversaries.

What Your Pen Test Must Cover for Each Framework

For CMMC purposes, the pen test scope centers on CUI systems: the networks, workstations, servers and applications that process, store or transmit controlled unclassified information. The methodology and evidence requirements follow the standard C3PAO framework: NIST 800-171 control mapping, SSP alignment and POA&M integration.

For CHIPS Act purposes, the scope expands to include systems that protect advanced manufacturing IP, process design files and fabrication technology. Fab OT systems, which may be largely excluded from a standard CMMC scope because they do not handle CUI directly, become relevant when the question is whether federal investment in those systems is adequately protected from nation-state actors. Supply chain interfaces with equipment vendors and technology partners are also in scope in ways that CMMC does not require.

Where the Evidence Requirements Diverge

CMMC evidence requirements are well-defined. C3PAO assessors know what they are looking for and how it maps to the 110 practices they evaluate. CHIPS Act federal program officers reviewing cybersecurity compliance are evaluating against a different standard, and the documentation they expect reflects a broader set of concerns about technology protection and supply chain security.

Running a single pen test engagement that produces two separate evidence packages, one structured for C3PAO review and one structured for CHIPS Act program officer review, is achievable but requires deliberate planning before the engagement starts. The scope must be broad enough to cover both sets of requirements. The reporting must be structured to address both audiences without requiring the pen test team to run two separate engagements.

Common Gaps in Semiconductor Pen Test Programs

The most common gap in semiconductor manufacturer pen test programs is fab OT exclusion. Engineering teams are understandably protective of cleanroom and process control systems, and standard OT scoping practices lead to those systems being excluded from scope entirely. That exclusion satisfies CMMC requirements, which do not mandate testing of non-CUI OT systems. It does not satisfy CHIPS Act expectations around protecting the manufacturing technology the federal investment is funding.

Supply chain interface testing is the second most common gap. Semiconductor manufacturers have complex vendor ecosystems involving equipment manufacturers, EDA tool providers and research partners. The access those relationships require is a significant attack surface that is rarely tested because it falls outside the boundaries of a standard enterprise pen test scope.

Building a Program That Satisfies Both

The most efficient path to dual compliance is a unified pen test program with a scope built from both frameworks simultaneously, not two separate programs run independently. That requires a security partner who understands both CMMC assessment requirements and the threat model that CHIPS Act cybersecurity conditions are designed to address.