What Is GCC High? Why Is It Critical for Compliance?

Quick Answer

Microsoft 365 GCC High is a government cloud environment for eligible organizations with specific U.S. government security, data-handling, and compliance requirements. Before adopting it, organizations should verify eligibility, contractual obligations, application compatibility, and migration costs. Using GCC High alone does not guarantee compliance with regulations such as CMMC, DFARS, or ITAR. 

Key Takeaways

• Microsoft 365 GCC High is designed for eligible organizations with specific U.S. government security, data-handling, and compliance requirements.
• Choosing between GCC and GCC High depends on contractual obligations, data sensitivity, and applicable regulatory requirements.
• Organizations must meet Microsoft’s eligibility criteria and complete the validation process before adopting GCC High.
• Successful migration requires planning for licensing, data, application compatibility, identity management, and security controls.

Data security and compliance are critical in today’s organizational environments, especially for those handling sensitive or proprietary information, such as those managed by U.S. government entities.

Unfortunately, cybercrime is a persistent problem across the board and the government is no exception to the vulnerabilities faced. According to statistics, the number of incident reports filed by federal agencies in fiscal year 2023 totaled more than 32,000, a 5% increase over 2022. You figure these are known attacks that have been discovered.

Government officials and IT decision-makers must consistently ask themselves how to keep their cloud-based data secure while following compliance rules. They obviously don’t want their sensitive data to be exploited, but with so many options, it can be difficult to assess which cloud and technology solutions are the most secure.

To solve the dilemma of how to safely store, handle and manage data, Microsoft has developed its Government Community Cloud (GCC) High and Standard GCC solutions. This highly secure cloud is specifically designed as a U.S.-specific option.

In this blog post, we’ll define GCC High and explore the key differences between standard GCC and GCC High, including their compliance frameworks (FedRAMP, DFARS, CJIS) and suitability for various industries. We’ll also take a look at why GCC High is essential for organizations aiming to secure government contracts or meet Defense Federal Acquisition Regulation Supplement (DFARS) requirements.

What is GCC High?

Microsoft’s GCC is a Platform as a Service (PaaS) that is built on Azure Commercial infrastructure but adheres to specific compliance frameworks and is designed to work in conjunction with government requirements.

You may have heard the phrase “GCC High” (GCCH) but might not be sure what it means. If you’re wondering “what is GCCH,” the best way to explain it is that it is a “next-level” PaaS, in part because it comes with far more stringent requirements. GCCH plays a critical role in meeting compliance and security requirements for organizations handling controlled unclassified information (CUI), export-controlled data (ITAR/EAR) and other regulated workloads.

The specialized cloud environment offered by GCC High is meant to meet the stringent compliance and security requirements of the U.S. Department of Defense (DoD). Essentially, it replicates DoD’s cloud architecture. Those who use it must be cleared and usually are individuals working for government agencies or government-approved contractors in positions where they are handling sensitive or government-controlled data.

Microsoft GCC vs GCC High

While they sound similar, there is a significant difference between GCC vs. GCC High. Both are stored in compliant and secure environments, but there are some distinctions. Microsoft personnel across the globe have access to GCC, but not GCC High. Other ways GCCH differs from standard GCC and DoD environments include the following:

Red River Tip: Before choosing between GCC and GCC High, review your contract’s security and data-handling requirements. The right environment depends on the information you process, your contractual obligations, and the compliance controls your organization must implement.

Features of GCC

• Operates as a part of the commercial cloud and can be accessed by Microsoft employees worldwide
• Ideal for agencies with standard government requirements (federal, state, local, tribal and territorial) and certain government contractors
• Sought by public educational institutions, government-linked healthcare entities and nonprofits working with government agencies
• It is cost-effective for agencies without as stringent security and compliance needs
• Complies with IL2, DFARS 252.204-7012, FedRAMP Moderate and DoD SRG Level 2

Features of GCC High

• GCC High is stored in a separate, U.S.-based location called Microsoft’s US Sovereign Cloud
• Individuals able to access GCC High must possess specific high-level security clearances
• Microsoft personnel accessing GCC High must be a U.S. citizen and have the right clearances
• GCCH is designed for managing highly sensitive data and offers stricter security measures
• GCC High goes above and beyond DoD CC SRG Level IL4 and ITAR (International Traffic in Arms Regulations)
• Meets DoD regulatory standards and is compliant with FedRAMP High, CMMC (Cybersecurity Maturity Model Certification) and DFARS (Defense Federal Acquisition Regulation Supplement) requirements
• GCC High is utilized by government organizations with stringent compliance needs

Essentially, federal, state and local governments may use GCC High, along with specific defense contractors or other businesses or contractors who process or hold DoD-controlled unclassified information (CUI).

Why Do Agencies Use GCC High?

Organizations should evaluate Microsoft 365 GCC High when their government contracts, regulatory obligations, or data-handling requirements call for the additional controls and compliance commitments offered by this environment. The decision should be based on specific contractual and regulatory requirements, rather than a general desire for stronger security.

GCC High may be appropriate in the following situations:

• Handling controlled information: The organization processes Controlled Unclassified Information (CUI) or other sensitive government data that requires the controls available in GCC High.
• Meeting defense contract requirements: A Department of Defense contract or a prime contractor’s contractual terms specify requirements that GCC High can help support.
• Managing export-controlled data: The organization handles technical data subject to International Traffic in Arms Regulations (ITAR) or other applicable export-control requirements and needs an appropriate cloud environment.
• Meeting specific compliance commitments: The organization needs the applicable FedRAMP High or DoD Security Requirements Guide Level 4 controls offered by GCC High for its Microsoft 365 workloads.

Before choosing GCC High, organizations should verify their eligibility, review the exact requirements in their contracts, confirm that the necessary Microsoft 365 features and integrations are available, and assess licensing costs and migration needs. They should also establish which workloads and users need to operate in the environment.

GCC High does not automatically make an organization compliant with every regulation. Compliance depends on the applicable service commitments, the organization’s own security controls, and how its systems and data are managed. Organizations whose requirements can be met by Microsoft 365 GCC may not need to adopt GCC High.

What are GCC High Eligibility Requirements?

Microsoft 365 GCC High is available to eligible government organizations and commercial organizations authorized to handle regulated government information. Before purchasing licenses, an organization must complete Microsoft’s eligibility validation process. Meeting a general security or compliance requirement does not automatically qualify an organization for GCC High.

Step 1: Confirm Your Organization’s Eligibility

Determine whether your organization qualifies as a U.S. government entity or a commercial organization that holds or processes regulated government information. Depending on the organization’s work, qualifying information may include Controlled Unclassified Information (CUI), Department of Defense (DoD) information, or data subject to International Traffic in Arms Regulations (ITAR).

Step 2: Identify the Applicable Government Requirements

Review the relevant contracts, subcontracts, and regulatory obligations to establish why your organization needs GCC High. Identify the type of information involved and the requirements that apply to its storage, processing, and transmission.

Step 3: Prepare Supporting Documentation

Microsoft determines the evidence required for validation based on the organization’s circumstances and application pathway. Depending on the case, supporting documentation may include:

• An active Commercial and Government Entity (CAGE) code or applicable System for Award Management (SAM.gov) registration.
• A government contract, subcontract, purchase order, or other evidence of an eligible government business relationship.
• A sponsor letter or other documentation establishing the need to handle regulated government information, if requested.

These are examples of possible supporting records, not a universal checklist. The documents required can vary by organization and validation pathway.

Step 4: Submit the Microsoft Validation Request

Start with Microsoft’s official Microsoft 365 Government eligibility and purchasing guidance. Follow the current instructions for submitting the eligibility form and providing any requested evidence. Microsoft may request additional information before making a decision.

Step 5: Complete Validation Before Purchasing

Wait for Microsoft to confirm eligibility, then work with the Microsoft account team or an authorized government cloud partner to purchase the appropriate licenses. GCC High trials are not currently available, so organizations should confirm their requirements and eligibility before planning a deployment.

Note: Eligibility validation is separate from implementing the security controls required by a contract or regulation. Approval to use GCC High does not, by itself, establish compliance with CMMC, DFARS, ITAR, or other applicable obligations.

Red River Tip: Start the GCC High validation process early. Gather relevant contract details and organizational documentation, then confirm the current eligibility and submission requirements with Microsoft or an authorized government cloud partner before planning your purchase.

How GCC Helps Organizations Meet Compliance Requirements

GCC is specifically developed and designed by Microsoft to meet security and compliance requirements set by the U.S. government. It helps organizations meet compliance standards like ITAR, EAR, DFARS and FedRAMP High.

Risks of Not Meeting Applicable Government Cloud Requirements

Using a cloud environment that does not meet an organization’s contractual or regulatory requirements can create compliance risks. However, GCC High is not mandatory for every government agency or contractor. The appropriate environment depends on the type of information handled, the terms of the contract, and the applicable security requirements.

If an organization uses an environment that lacks the required protections or compliance commitments, it may face consequences such as:

• Contractual issues: Failure to meet specified data-handling or security requirements could jeopardize contract eligibility, renewal, or performance.
• Regulatory exposure: Inadequate controls over regulated information may result in findings during compliance assessments or audits.
• Data security risks: An environment that does not provide the required access restrictions or data protections may expose sensitive government information to unauthorized access.
• Financial and reputational damage: Addressing compliance gaps can require additional investment, remediation, and operational changes. Serious failures may also affect customer confidence and future business opportunities.

Organizations should review their contracts, identify the regulations that apply to their workloads, and verify that their chosen cloud environment provides the necessary protections. Where requirements call for GCC High, they should confirm eligibility and plan an appropriate deployment. Where GCC meets the applicable requirements, moving to GCC High may not be necessary.

Using GCC High alone does not guarantee compliance. Organizations remain responsible for implementing and maintaining the security controls required by their contracts and applicable regulations.

How to Rectify Non-Compliance of GCC High

Businesses not compliant with GCC High should assess their needs and evaluate the type of data they handle; if necessary, consult with experts who are well-versed from the perspectives of IT and legal. If your business is not currently approved for GCC High, begin the process to obtain validation from Microsoft, so your company can achieve compliance by migrating to the more secure GCC High cloud option. Additionally, you’ll want to evaluate existing security controls and implement stronger ones where necessary.

Summary

Microsoft’s GCC High is a specialized and powerful cloud solution designed to accommodate the stringent compliance requirements of the U.S. government, especially for those entities handling sensitive data. It provides groups and individuals with the security clearances needed the ability to enjoy Microsoft’s tools, such as Teams, Office 365 and Azure, but in a more secure environment.

While it is a part of the broader GCC option offered by Microsoft, GCC High is structured as a separate cloud environment to provide the high-level security necessary for many governmental entities. GCC High data centers can only operate in the United States and only cleared personnel may have access to them, including Microsoft employees.

Migrating to GCC High requires approval, along with in-depth planning and execution. To successfully accomplish this, companies need to connect with an AOS-G partner who can help get validation and provide assistance and knowledge to complete a smooth transition.

Need Assistance Obtaining GCC High Approval? Red River is an AOS-G Partner

If you are a government contracting company and need to elevate your security and compliance practices to fulfill the terms of a current or potentially future contract, Red River can help. As an approved AOS-G Partner for Microsoft, our team of experts has the in-depth knowledge and experience your company needs to assist your business in obtaining validation and making the transition to GCC High.

Red River has over 25 years of experience serving customers in the commercial, federal and SLED markets. As a leading company with technical expertise, along with a personal touch, we fully understand your mission and can offer the right technology solution suited to meet your needs.

To schedule a consultation, contact Red River today. Let’s get the conversation started. We’re happy to answer any questions or provide more information about GCC, GCC High or any other technology topics.

Frequently Asked Questions