If your organization handles Controlled Unclassified Information (CUI), you may be wondering: Do we really need GCC High? It's a fair question—and one that comes up often. While there are limited scenarios where Microsoft 365 GCC might be sufficient, most contractors handling CUI will eventually need to migrate to GCC High to meet compliance and contractual obligations.
Here’s what you need to know.
1. What the Regulations Actually Say
Frameworks like DFARS 252.204-7012, CMMC, and NIST 800-171 outline specific requirements for how CUI must be stored, processed, and protected. These include:
FedRAMP High authorization
U.S. data residency and personnel access
Advanced audit logging, encryption, and access control capabilities
Microsoft 365 Commercial does not meet these requirements. Microsoft 365 GCC partially does, but GCC High was purpose-built to satisfy the strictest of them.
2. Your Customers May Decide For You
Even if you believe your setup is “good enough,” your prime contractor or government customer might disagree. Increasingly, they’re requiring that subcontractors:
Operate in a GCC High tenant
Show proof of data residency and audit controls
Demonstrate a plan for CMMC Level 2 or 3 compliance
Working with a provider of GCC High migration serviSSces positions you to meet these expectations and preserve your eligibility in the federal supply chain.
3. There Are No Shortcuts Around Compliance
Trying to force-fit CUI handling into a noncompliant tenant puts your business at risk:
Failed audits
Breach of contract
Ineligibility for future awards
Exposure to penalties under DFARS or ITAR
4. GCC High Isn’t Overkill—It’s Insurance
Yes, GCC High costs more than Commercial or GCC. But it also:
Reduces compliance guesswork
Provides a secure baseline for all future federal work
Strengthens your position in competitive bids
When your business depends on federal contracts, investing in the right environment is part of your risk management strategy.