What is CMMC Compliance? Getting started with CMMC 2.0

What is CMMC 2.0?

U.S. Department of Defense (DoD) contractors and subcontractors are prime targets for cyberattacks, putting sensitive government data at risk. To enhance cybersecurity within the Defense Industrial Base (DIB), the DoD introduced the Cybersecurity Maturity Model Certification (CMMC) program. The final rule for CMMC 2.0 was published on December 15, 2024.

CMMC compliance focuses on implementing security controls to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in nonfederal systems. All DoD contractors and subcontractors must achieve CMMC certification to confirm adherence to required cybersecurity standards. Meeting CMMC requirements ensures eligibility for defense contracts and strengthens overall cyber resilience.

CMMC Requirements for Defense Industrial Base (DIB) Contractors

All Defense Industrial Base (DIB) contractors and subcontractors must comply with Cybersecurity Maturity Model Certification (CMMC) requirements. The required CMMC certification level depends on the type of sensitive information handled, such as Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). Higher CMMC levels impose stricter cybersecurity controls, ensuring enhanced protection against cyber threats. Achieving the appropriate CMMC compliance level is essential for maintaining DoD contract eligibility and securing critical government data.

CMMC Level 1

Organizations handling FCI are required to meet CMMC Level 1. FCI is “information, not intended for public release, that is provided by or generated for the Government under a contract to develop or deliver a product or service to the Government, excluding information provided by the Government to the public (such as that on public websites) or simple transactional information, such as that necessary to process payments.” Organizations can perform an annual self-assessment and self-affirmation.

CMMC Level 2

DIB organizations handling CUI must achieve CMMC level 2. CUI is  “information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls.”  Organizations must achieve certification tri-annually by an accredited C3PAO and perform an annual self-affirmation.

CMMC Level 3

CMMC level 3 provides increased assurance to the DoD that an organization can adequately protect CUI at a higher level of protection against adversarial risk from advanced persistent threats (APTs). Organizations must first achieve CMMC level 2 certification, then level 3 certification assesses additional protection against advanced persistent threats (APTs), performed by a Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) assessor every three years with annual affirmation.

The CMMC Certification Process

As with many compliance frameworks and certifications, CMMC is a journey with multiple stages. All CMMC certification activities are focused on achieving the desired level of CMMC certification. Before pursuing a C3PAO audit of CMMC compliance, organizations need to prepare and ensure that the environment is CMMC assessment ready. Preparation may require the design and building of systems that meet boundary requirements for handling sensitive information and the addition of security controls required to meet a CMMC-level requirement.

Building and testing a CMMC environment

The design and build of a CMMC environment must implement required boundaries and enforce cybersecurity controls. The CMMC requirements exceed those of many other frameworks and may exceed your current implementation or require building environments that will fulfill the requirements for a successful CMMC certification. Since CMMC builds upon many other government compliance frameworks, organizations experienced with these environments can develop and test an environment for a successful CMMC certification.

Assessing and certifying a CMMC environment

A certified C3PAO must assess a CMMC environment. C3PAO organizations are certified by Cyber AB, the official accreditation body of the CMMC ecosystem and the sole authorized non-governmental partner of the U.S. DoD in implementing and overseeing the CMMC conformance regime. A C3PAO with federal and DoD compliance experience (e.g., FedRAMP, IL6, NIST 800-171, CMMC) can perform the certification process with less cost and delay.

Avoiding Common CMMC Pitfalls

CMMC scoping. Many organizations fail to properly define their CMMC scope, leading to confusion about which systems, processes, and data fall under the certification requirements. This failure often results in an over-scoped environment, inflating costs and complexity or under-scoping the environment that may lead to non-compliance.

Overlooking third-party providers. Ignoring the compliance posture of third-party vendors and service providers can create significant vulnerabilities and non-compliance risks.

Over confidence in security posture. Many organizations assume their existing cybersecurity measures meet CMMC Level 2 requirements, only to discover gaps during the pre-assessment or formal assessment.

Misreading readiness and gaps. Some organizations treat the readiness assessment as a box-checking exercise rather than a comprehensive evaluation of their compliance posture. This failure leads to a false sense of security and unanticipated findings during the formal assessment.

Achieving CMMC Certification

CMMC certification is mandatory for Defense Industrial Base (DIB) contractors and demonstrates a strong commitment to cybersecurity and protecting sensitive information. Picking an experienced partner with the expertise to help guide DIB organizations through the certification process is critical, ensuring they are assessment-ready and fully prepared to meet federal compliance standards. Selecting the right CMMC partner helps streamline certification, mitigate security risks, and maintain eligibility for DoD contracts.