Microsoft 365 Commercial is a powerful platform—but if your organization handles Controlled Unclassified Information (CUI), it might not be enough. Many government contractors assume that enabling security features in their current tenant is sufficient for compliance. Unfortunately, that assumption can lead to failed audits, contract disqualification, and serious risk.
Let’s explore why Microsoft 365 Commercial falls short for CUI and how GCC High migration services can close the gap.
1. Data Residency and Administrative Controls
CUI must be protected in environments with strict U.S. data residency and personnel access requirements. Microsoft 365 Commercial:
Does not guarantee U.S.-only data residency
Allows administrative access from global support teams
Does not meet ITAR or DoD SRG IL4/IL5 standards
In contrast, Microsoft GCC High ensures that both your data and administrative controls stay within U.S. borders—by screened U.S. personnel only.
2. No Support for Certain Compliance Frameworks
If you’re targeting CMMC Level 2 or 3, or if your contracts include DFARS clauses, commercial tenants aren’t built to meet those needs. Microsoft has explicitly stated that Commercial 365:
Is not authorized to store or process CUI
Cannot meet full NIST 800-171 control requirements
Should not be used for defense-related workloads
That’s why contractors turn to GCC High migration services to move into a compliant, audit-ready tenant that supports their federal obligations.
3. Feature Limitations Create Risk
Even with best practices, certain CUI controls can’t be enforced reliably in the Commercial environment. For example:
Limited availability of advanced auditing and logging
Constraints in applying role-based access and device trust
Gaps in aligning Conditional Access with DFARS/NIST standards
These technical limitations make Commercial a liability—even for highly disciplined IT teams.
4. Licensing Doesn’t Equal Compliance
Having Microsoft 365 Business Premium or E5 licenses in a Commercial tenant may give you security features—but it doesn’t give you compliance. GCC High tenants come with the compliance boundary necessary for regulated industries.
5. Migration Isn’t Just a Fix—It’s a Strategic Move
Migrating to GCC High early allows your team to:
Align policies and tools with federal frameworks
Reduce audit risk and eliminate compliance gaps
Support future contract growth with a secure foundation