An Overview of the Cybersecurity Maturity Model Certification (CMMC)

Developed by the US Department of Defense (DoD), the Cybersecurity Maturity Model Certification (CMMC) is a standard for implementing cybersecurity measures across their supply chain and network of contractors. The DoD engages with over 300,000 contracting companies across the Defense Industrial Base (DIB) in the acquisition of technologies, products, and services.

To perform their duties, contractors require access to Controlled Unclassified Information (CUI). Prior to the CMMC, contractors were required to implement, and self-regulate their information security systems to protect the CUI. Due to gaps in the previous regulation, there have been significant compromises of sensitive defence information across contractors' databases and information systems - ultimately leading to the creation of the certification.

With the CMMC, contractors are still responsible for developing controls and maintaining the security of their information technology systems, but the assessment of their information systems and compliance audit are performed by an accredited third-party or C3PAO

What Is The CMMC Framework?

The CMMC framework encompasses 17 capability domains mapped across 5 levels, each with organized processes and respective cybersecurity best practices. The levels measure the maturity level and technical capabilities of a company's cybersecurity infrastructure with how it protects sensitive defense information across their information systems.

Here is an overview of the 5 levels with the practices, processes, and relations to existing regulations and frameworks.

• Level 1: This level performs basic cyber hygiene, e.g., regularly changing passwords. Its practices are equivalent to those in the Federal Acquisition Regulation (FAR) 48 CFR 52.204-21. This is about the basic safeguarding of the Federal Contract Information (FCI). 

• Level 2: This is a transitional documentation step towards the protection of Controlled Unclassified Information. It is concerned about intermediate cyber hygiene. It includes a select subset of 48 practices from the NIST SP 800-171 r1 and complies with the FAR. 

• Level 3: Management of processes that protect CUI and good cyber hygiene is done at this level. It encompasses all the practices from NIST SP 800-171r1 and complies with the FAR. 

• Level 4: This is the proactive cybersecurity level that reviews implemented processes and the effectiveness of practices. This level complies with FAR, encompasses all practices from NIST SP 800-171 r1, and includes a select subset of 11 practices from Draft NIST SP 800-171B.  

• Level 5: Optimizing advanced/progressive cybersecurity practices occurs at this level. The level encompasses all practices from NIST SP 800-171 r1, includes a select subset of 4 practices from Draft NIST SP 800-171B, and complies with FAR. 

Levels 4 and 5 secure CUI and require active cybersecurity processes and reduce the risk of advanced persistent threats (APTs).

What Is Controlled Unclassified Information (CUI)?

Controlled Unclassified Information, often abbreviated as CUI, refers to sensitive government data that isn’t classified at the top-secret level, but still requires safeguarding under federal regulations. This could include technical drawings, research data, contract details, or even certain emails containing export-controlled technical information. For defense contractors, protecting CUI is crucial: it’s the kind of information that, if leaked, could pose risks to national security or compromise defense strategies.

Think of CUI as that folder on your desktop you wouldn’t want falling into the wrong hands—not because it’s earth-shattering, but because it could give competitors, cybercriminals, or even nation-states a leg up. This is why the Department of Defense and other federal agencies have drawn a clear line in the sand, requiring firms in the supply chain to adopt robust safeguards for this information.

The CMMC was designed specifically to create consistency in how CUI is protected—so whether you’re a subcontractor in Silicon Valley or a small manufacturer in Ohio, the standard for cybersecurity remains the same.

What Does CMMC Cover?

The CMMC framework applies to all organizations within the DoD supply chain that process, store, or transmit CUI. This includes both prime contractors and subcontractors, regardless of their size or the specific technologies they provide. Whether your organization handles logistics, manufactures components, or manages IT infrastructure, CMMC requirements are now a core part of doing business with the DoD.

CMMC is designed as a unifying standard, drawing from widely recognized security frameworks such as NIST SP 800-171, ISO 27001, and others. This ensures a consistent approach to cybersecurity maturity and reliability across the entire Defense Industrial Base.

Why Is CMMC Important?

Given the increasing sophistication of cyber threats and the volume of sensitive information exchanged within the defense sector, the CMMC represents a significant shift from self-attestation to verified compliance. By introducing third-party assessments, the DoD aims to reduce vulnerabilities and better secure critical data that supports national defense.

Whether you’re a large enterprise or a small subcontractor, understanding and implementing the CMMC framework is essential for maintaining eligibility for DoD contracts and protecting the integrity of national security information.

What About CMMC Compliance?

The CMMC applies to entities required to protect CUI or safeguard sensitive defence information related to the DoD's procurement processes. Hence, all DoD contractors, subcontractors, and all suppliers along the supply chain will need to comply with the CMMC. In case of non-compliance, there won't be bidding for the contractors.

Once you're ready for the CMMC assessment, you’ll proceed through a structured set of phases led by an accredited C3PAO. By breaking the assessment process down into the following phases, organizations can both anticipate what lies ahead and better allocate resources, supporting a streamlined path to successful CMMC certification:

1. Pre-Assessment Preparation

This initial stage involves collaboration with the assessment team to establish the scope of the review. You'll identify key contacts, assemble relevant documentation, and clarify timelines. The main focus here is to set clear expectations and gather all necessary information, paving the way for a smooth assessment.

2. The Assessment Itself

Here, the assessors will formally kick off the evaluation—often with an opening meeting to align everyone and confirm the ground rules. Your organization's systems and practices will then be examined for compliance with the required CMMC level. Assessors review your evidence, discuss any potential gaps or concerns, and collect findings throughout the process.

3. Post-Assessment Review and Reporting

After the assessment, results and observations are compiled into a comprehensive report. A quality assurance review follows, not only within the assessment organization but also by the CMMC Accreditation Body (CMMC-AB). The CMMC-AB then makes the final determination, issuing or denying the requested certification level based on the findings.

4. Remediation (if necessary)

If the assessment uncovers minor gaps that prevent certification, your organization may be granted a set period (typically 90 days) to address the deficiencies. During this window, you’ll work to remediate shortfalls and demonstrate improved compliance. Once the fixes are validated, those results are shared with the CMMC-AB for a final review.

Remediation When Requirements Aren’t Met

If, during the assessment, an organization falls short of the required CMMC practices, there’s still an opportunity to achieve compliance—though it comes with a strict timeline. In such situations, a remediation plan must be submitted to the CMMC Accreditation Body (CMMC-AB) for review and approval.

Should the proposed remediation be accepted, companies are granted a 90-day window to address and resolve any deficiencies identified during the assessment. This period is critical; all missing practices must be implemented and verified within those 90 days to secure certification at the desired maturity level.

Failing to close these gaps within the allotted time can delay or jeopardize the certification process, potentially excluding the organization from DoD contract opportunities until compliance is fully demonstrated.

Eight Steps to Achieve CMMC Certification

For defense contractors and subcontractors, navigating the path to CMMC certification can feel like assembling a particularly challenging jigsaw puzzle—except this one’s under the scrutiny of the Department of Defense. Here’s a practical, step-by-step roadmap to help your organization prepare for and achieve CMMC certification, ensuring your contracts (and sleep) remain intact:

1. Implement and Assess Security Measures
   Begin by creating a thorough System Security Plan (SSP) and perform a self-assessment aligned with NIST SP 800-171 standards. This initial review will help you pinpoint where your organization already meets requirements and where the gaps lurk.

   
   

2. Develop and Submit Your Compliance Score
   Based on your self-assessment findings, develop a Plan of Actions and Milestones (POA&M) to address any shortfalls. Assign target dates for remediation, then submit your current compliance score to the Supplier Performance Risk System (SPRS).

   
   

3. Define the Scope of Assessment
   Clarify which parts of your organization need certification—this could be your whole enterprise, a business unit, or even just an isolated program enclave. This focus makes preparation much less overwhelming.
   
   

4. Opt for a Preliminary Gap Assessment
   While optional, scheduling a preliminary gap assessment with a credentialed third-party assessment organization can be incredibly helpful. This step flags potential vulnerabilities so you can shore them up early.
   
   

5. Address Findings and Close Security Gaps
   Take the lessons from your gap assessment and set about plugging the holes, updating processes, and making sure your documentation and controls reflect the required practices.

   
   

6. Select an Accredited Assessment Organization (C3PAO)
   With your security controls in good shape, select a certified third-party assessment organization from the Cyber-AB Marketplace. Get on their calendar for your official CMMC assessment.
   
   

7. Undergo the CMMC Assessment
   The formal assessment is a structured exercise, typically following four phases:

   • Pre-Assessment Planning: Finalize assessment scope, team, and documentation.

   • Assessment Execution: Participate in opening meetings, provide evidence, and work with auditors as they review your controls and processes.

   • Post-Assessment Reporting: After the review, the assessment organization consolidates findings and submits a recommendation to the CMMC Accreditation Body for further quality assurance checks.

   • Remediation (If Needed): Should any controls fall short, you may be granted up to 90 days to fix them and demonstrate compliance.
     
     

8. Achieve Certification
   Once all requirements are satisfied, your assessment organization will upload the results for review. If everything is in order, you’ll receive either a final three-year CMMC certification or a conditional one—pending closure of outstanding corrective actions.

By following these eight steps, defense contractors set themselves up for successful CMMC compliance—and continued eligibility for contracts throughout the defense industrial ecosystem.

Achieving Final or Conditional CMMC Level 2 Certification

Once your organization has completed the CMMC assessment, the results are reviewed by a quality assurance specialist from your chosen Certified Third Party Assessment Organization (C3PAO). If your company meets all the required practices and processes for Level 2, you will be granted a Final CMMC Level 2 certification, which is valid for three years.

However, if the assessment identifies outstanding items that need to be addressed—typically documented in a Plan of Actions and Milestones (POA&M)—your organization will receive a Conditional CMMC Level 2 certification. To move from conditional to a final certification, you'll need to remediate the identified gaps within the specified timeframe. Once the corrective actions are verified and closed, your company may then qualify for the full three-year CMMC Level 2 certification.

Defining the Scope of Your CMMC Assessment

Determining the scope for your CMMC assessment is a crucial early step. Organizations should carefully consider which environments, business units, or program enclaves are involved in handling Controlled Unclassified Information (CUI). This means mapping out where CUI resides, transits, or is processed within your systems or networks.

For some, scope might cover the entire enterprise, while others may limit assessment to specific divisions or project enclaves tied to DoD work. Be thorough—overlooking a system or location can create compliance gaps and risk the success of your certification. As of now, the Cyber-AB (the accreditation body for CMMC) has published assessment guides for Levels 1 and 2, so be sure to reference the latest guidance as you define your organization's boundaries.

By clearly documenting this scope, you’ll streamline the assessment process and ensure that you target your resources where they matter most for CMMC compliance.

What Is a Preliminary Gap Assessment and Why Is It Recommended?

A preliminary gap assessment serves as a dress rehearsal for your formal CMMC audit. Conducted by an independent third-party organization, this assessment involves a thorough review of your current information security practices, policies, and technical controls. The primary purpose is to pinpoint where your systems align with CMMC requirements—and, more importantly, where they fall short.

Why bother with this extra step? Essentially, a preliminary gap assessment lets you identify and address weak spots before the official audit. This proactive approach helps reduce surprises, guides your remediation efforts, and increases the likelihood of achieving your desired certification level on the first attempt. It also gives your internal team a clearer understanding of what independent assessors will be looking for, allowing you to develop a more targeted and effective action plan.

Choosing a CMMC Third Party Assessment Organization (C3PAO)

Once security gaps have been addressed and your organization is ready for assessment, the next step is to select an accredited C3PAO to review your CMMC readiness.

To do this, head over to the Cyber-AB Marketplace—a directory of all authorized C3PAOs—and review available options. When selecting a C3PAO, consider factors such as:

• Their experience with organizations of your size and industry

• Availability to conduct assessments within your timeline

• Familiarity with your desired CMMC level

• Feedback or testimonials from other contractors

Once you've compared your options, reach out to your chosen C3PAO to schedule your official CMMC assessment. This ensures you are evaluated by a qualified and impartial party, in line with the certification’s requirements.