CMMC compliance has been a long time coming, and if you're a government contractor working with the U.S. Department of Defense (DoD), 2025 marks a critical turning point.
Let's take a look at the details on achieving CMMC compliance. Even if you're late to the game, certification is still possible!The Cybersecurity Maturity Model Certification (CMMC) 2.0 is no longer "coming soon." It's active. Assessments have begun. Contract requirements are on the way. If you want to continue doing business with the DoD, or break into the defense industrial base (DIB), preparing for CMMC compliance needs to be your top priority.
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In this guide, we'll walk you through what's happening, why it matters, and how your organization can successfully navigate the new requirements before it's too late.
Cybersecurity threats are evolving faster than ever before. Espionage, intellectual property theft, and cyberattacks from nation-state actors have escalated dramatically. In response, the DoD is moving from a "trust-based" model to one based on verified cybersecurity maturity.
CMMC 2.0 isn't just a compliance exercise. It's a critical piece for protecting sensitive government information across the supply chain. Companies that treat CMMC as an afterthought risk falling behind — or losing contracts entirely.
The landscape shifted significantly when the final CMMC program rule (32 CFR Part 170) took effect in December 2024. While assessments have already started, CMMC requirements will begin appearing in DoD contracts after the CMMC Acquisition Rule (48 CFR) finalizes, anticipated in early to mid-2025.
The rollout will happen in phases but make no mistake: waiting is not a strategy. Preparing for CMMC certification can take anywhere from 6 to 18 months, depending on your starting point.
Organizations that delay action risk missing out on future opportunities.
Before you can prepare, you need to understand what level of certification your business requires.
Level | What It Covers | Assessment & Requirements |
Level 1 Basic Cyber Hygiene |
For companies handling Federal Contract Information (FCI) only. Example: Office supplier for a DoD base. | 15 basic practices per FAR 52.204-21. Annual self-assessment. No POAMs allowed. |
Level 2 Advanced Cybersecurity |
For contractors working with Controlled Unclassified Information (CUI). Example: Aerospace parts manufacturer. |
110 controls from NIST SP 800-171 Rev. 2. Third-party assessment every 3 years (or self-assessment for some). |
Level 3 Expert Cybersecurity |
For organizations supporting DoD’s most critical programs. Example: Prime contractor with classified systems. |
All Level 2 + 24 enhanced controls from NIST SP 800-172. Government-led assessment (DIBCAC). |
This level applies to companies that handle only Federal Contract Information (FCI), such as a small supplier providing general office equipment to a DoD base. Even though the data involved may seem low-risk, these companies must still implement 15 basic cybersecurity practices aligned with FAR 52.204-21.
Certification is achieved through an annual self-assessment, and every control must be fully met — no Plans of Action and Milestones (POAMs) are permitted. Maintaining even basic protections like secure passwords, access controls, and system monitoring is essential to meeting Level 1 requirements.
Level 2 certification is where most defense contractors will fall, particularly businesses handling Controlled Unclassified Information (CUI), such as an aerospace component manufacturer that accesses sensitive design files. To achieve certification, organizations must comply with 110 security controls outlined in NIST SP 800-171 Rev. 2. Most contracts at this level will require a third-party assessment every three years, although certain lower-risk contracts may permit a self-assessment instead.
Level 3 is reserved for contractors working on the DoD’s most critical and sensitive programs, such as a prime contractor developing classified defense systems or advanced technologies. This highest level of certification builds on Level 2 requirements, adding 24 enhanced cybersecurity controls from NIST SP 800-172 to defend against advanced persistent threats. Certification at this level requires a government-led assessment conducted by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
Many companies underestimate what's involved in a CMMC assessment. It's not just a technical review — it's a full validation of your cybersecurity maturity.
Expect to:
If you're granted certification, you must also complete an annual affirmation of ongoing compliance through the Supplier Performance Risk System (SPRS). Skipping this step risks losing your certified status.
Preparation is everything. And it starts with knowing what assessors will expect to see — and being ready to prove it.
Related Reading: CMMC 2.0 Compliance For DoD Contractors
Understanding these core concepts will make the path to CMMC certification clearer and help you avoid costly missteps.
Classifying your data correctly is fundamental. FCI (Federal Contract Information) requires basic protection, while CUI (Controlled Unclassified Information) demands more advanced controls and typically a third-party assessment. Misclassification could lead to unnecessary costs or worse—noncompliance.
Plans of Action and Milestones (POAMs) allow limited flexibility by letting you temporarily address certain non-critical gaps. However, POAMs can’t cover essential controls, must meet a minimum score threshold, and have a strict 180-day remediation deadline. Relying on them too heavily is risky.
CMMC certification isn't a one-and-done process. Every year, a senior official must affirm that your organization remains compliant. Missing this step means your certification lapses—and your DoD contracts could be at risk.
Prime contractors are responsible for ensuring their subcontractors meet CMMC requirements if they handle FCI or CUI. If a subcontractor drops the ball, you could be held accountable. This makes vetting and ongoing oversight essential.
These aren’t just technicalities—they’re the foundation of your long-term eligibility for DoD contracts under CMMC 2.0.
No contractor sets out to fail, but these missteps are alarmingly common:
Inaccurate Scoping Failing to properly define your environment can inflate costs — or leave critical gaps that doom your assessment.
Insufficient Documentation No matter how good your technical controls are, if you can't prove them with documented evidence, you won't pass.
Underestimating Time and Cost Preparing for CMMC is a major project. Without a realistic timeline and sufficient budget, you're setting yourself up for painful surprises.
Neglecting Employee Training Employees are the frontline. Without training, even the best systems can be undone by human error.
Ignoring Subcontractor Compliance A weak link in your supply chain can cost you the entire contract. Subcontractor management is mission-critical.
Avoid these pitfalls, and your path to certification will be far smoother.
Knowing what to do is half the battle. The other half is doing it.
Following these steps can mean the difference between winning new DoD work — and missing out.
CMMC 2.0 isn't just about passing an assessment. It's about building a sustainable, defensible cybersecurity posture that sets your company apart.
Organizations that treat cybersecurity maturity seriously will be better positioned to:
Compliance takes time, resources, and serious commitment. But it's also an investment in your future viability.
Start preparing now. The earlier you act, the better positioned you'll be when CMMC requirements become the new normal.