The Final Rule for the new Cybersecurity Maturity Model Certification (CMMC) framework, known as CMMC 2.0, took effect on December 16, 2025, signaling a dramatic shift in the global cybersecurity landscape.  

CMMC 2.0 came with a raft of changes, including a phased implementation model that would see the program rolled out over the next several years. That flexibility has seen many defense suppliers questioning the urgency of CMMC certification, with some wondering whether adopting the new framework is imperative in the first place.  

We’ve prepared a definitive answer to some of the most frequently asked questions about CMMC 2.0 compliance. But first, let’s start from the beginning by demystifying what this framework is all about. 

Unveiling CMMC

The Cybersecurity Maturity Model Certification is a program developed by the US Department of Defense (DoD) to safeguard the Defense Industrial Base (DIB) supply chain from cyber-attacks. CMMC compliance is notably a requirement for DIB companies that handle Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).  

The CMMC framework originated in 2010, following President Obama’s signing of Executive Order (E.O.) 13556. This order standardized how federal agencies handle CUI, laying the foundation for CMMC’s development.  

In 2020, the DoD issued the first iteration of the CMMC program, known as CMMC 1.0. The framework underwent a raft of amendments over the following years, culminating in the release of CMMC 2.0 in 2024. 

About CMMC Certification

CMMC certification is a standardized process that validates defense contractors’ compliance with the CMMC framework.  

The DoD requires DIB companies to undergo mandatory routine assessments annually or triennially, depending on an organization’s CMMC maturity level. The audited business is scored based on compliance with relevant CMMC controls, with the final scores determining whether certification can be issued.  

Granted, CMMC certification is a daunting and resource-intensive project. But there’s much to gain and nothing to lose for companies that attain full compliance.     

Is CMMC Certification Mandatory?

According to the CMMC Final Rule published in the Federal Register, implementing the CMMC framework is mandatory for any organization that seeks to conduct business with the Department of Defense.  

While there are exceptions for businesses that fall below the micro-purchase threshold of $10,000, CMMC certification is critical for any DIB entity that handles FCI or CUI.  

What Are the Perks of CMMC Certification?

The US Department of Defense is a significant consumer, with annual budgets nearing the trillion-dollar mark.  

In the Financial Year 2025, the DoD maintained its spot as the world’s best-funded military, with an annual spending of $916 billion. That was more than the total expenditure of the following eight countries, including the US military archrivals China ($296 billion) and Russia ($109 billion).  

Obtaining CMMC certification provides a lucrative opportunity to supply the DoD with essential goods and services.  

While you may not immediately rise through the ranks of top defense suppliers like Lockheed Martin, CMMC compliance significantly increases your eligibility for defense tenders. Besides, there are multiple services to offer besides tactical gear.  

 

Consequences of Skimping on CMMC Certification

Disregarding CMMC requirements can attract pretty hefty penalties.  

The Department of Defense can terminate existing contracts for noncompliance, resulting in major financial losses to the affected companies.  

Besides tender cancellations, the DoD may bar you from competing in future tendering processes. This could essentially lock you out of lucrative defense contracts, further impacting your business’s fortunes.  

The DoD might also prescribe direct fines for non-compliant DIB companies. According to the federal agency, vendors that misrepresent their compliance status may be slapped with fines up to $10,000 per control under the False Claims Act (FCA). Considering that CMMC Level 2 has up to 110 controls, the full extent of financial losses is simply unimaginable.  

In severe infractions, noncompliance may attract lengthy prison sentences. Therefore, there can never be a more opportune time to seek CMMC certification services.  

A classic example of the costly consequences of noncompliance is best exemplified in the Pennsylvania State University (Penn State) case, in which the institution was accused of ignoring critical federal cybersecurity protocols in DoD and NASA contracts. Penn State agreed to a $1.25m settlement following reputation-damaging allegations that it specifically failed to implement cybersecurity controls outlined in the NIST Special Publication 800-171 – the very framework that CMMC is based on. 

Other Adverse Effects of CMMC Noncompliance

1. Loss of Sensitive Data

Obtaining CMMC certification is a critical step towards thwarting cyber-attacks, not only across the defense supply chain but also in your information systems.  

Failure to implement proper cybersecurity controls can lead to losing sensitive information, including financial data and trade secrets. 

2. Operational Downtime

Skimping on CMMC certification exposes your information systems to advanced cyber-attacks, whose occurrence can cripple your business operations.  

Depending on the impact of a breach, downtimes can run into days and cause millions in lost income. 

3. Reputational Damage

Cyber-attacks can erode confidence in your brand and trigger consumer exodus. The consequences are grimmer where a breach causes large-scale exfiltration of sensitive consumer data.  

Pursuing certification provides the safest pathway to maximizing defense opportunities and safeguarding your brand’s reputation.

4. Legal Repercussions

Failure to obtain or renew your CMMC certification can lead to noncompliance with the framework, resulting in lawsuits by the DoD. But that could only be the beginning of your legal woes.  

Your company’s other stakeholders may also sue you for negligence, leading to millions of dollars in compensation.  

How Many CMMC Certification Levels Are There?

The new CMMC framework has three distinct maturity levels, including; 

CMMC Level 1 (Foundational)

CMMC Level 1 is strictly for DIB companies that handle Federal Contract Information.  

To obtain CMMC compliance under this maturity level, you must undergo mandatory self-assessment and affirm your compliance with 17 controls in NIST SP 800-171 to the Supplier Performance Risk System (SPRS). 

CMMC Level 2 (Expert)

Level 2 certifications are issued to DIBs upon undergoing triennial cybersecurity audits by CMMC third-party assessor organizations (C3PAOs). Vendors seeking compliance under the Expert level must fulfill at least 88 of the 110 controls in NIST 800-171, with each evaluation returning a “Met” or “Not Met” verdict.  

A ‘Met’ score means that your organization is fully compliant with all 110 controls, while a ‘Not Met’ verdict indicates the assessment uncovered glaring gaps. If the identified weaknesses exceed 20%, you’re automatically deemed noncompliant, and the DoD may prescribe penalties accordingly.  

However, you receive provisional certification for a score over 80%, granting you up to 180 days to remediate the risks uncovered in a Plan of Action and Milestones (POA&M) document.  

CMMC Level 2 targets both FCI and CUI. While certifications are typically reviewed triennially, the DoD requires self-affirmations annually.  

CMMC Level 3 (Advanced)

CMMC Level 3 certifications are the most difficult to obtain, understandably due to the rigorous assessment process involved. The maturity level was developed to protect the defense supply chain against Advanced Persistent Threats (APTs).  

Organizations seeking Level 3 certifications must comply with all Level 2 controls plus additional protocols outlined under NIST 800-172. Cybersecurity assessments under this level are strictly overseen by auditors appointed by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). 

What Does The Certification Process Entail?

The first step in obtaining CMMC certification is to understand the CMMC maturity level applicable to your business. To do that, you’ll need to scope your organization’s systems for sensitive information.  

If your company strictly handles FCI, you’re only obligated to apply for CMMC Level 1 certifications. Certification for subsequent levels will be required for CUI.  

The next steps in CMMC certification would typically unfold as follows;

1. Develop an SSP

A System Security Plan (SSP) is a comprehensive document that outlines the cybersecurity controls and procedures an organization has implemented or plans to implement to safeguard its information systems.  

SSPs serve as blueprints for storing, handling, and disseminating sensitive information.

2. Conduct a gap analysis

Although optional, preliminary gap analysis is an important step in CMMC assessment.  

You can self-audit through your in-house cybersecurity team or enlist CMMC certification services for unbiased perspectives.

3. Implement remediation

It’s best to remediate any gaps uncovered during preliminary audits ahead of official assessments. Each weakness addressed should translate into updating your SSP.

4. Contract third-party assessors

If you’re seeking CMMC Level 1 certification, the next step after sealing security weaknesses detected in preliminary assessments is to report your self-audit reports to the SPRS.  

However, for Levels 2 and 3 certification, you’ll need to engage relevant third-party assessors. That would be a C3PAO or a DIBCAC official, respectively. 

5. Obtain certification

All findings from CMMC audits must be reported to the SPRS. The DoD would carefully analyze each report before awarding, renewing, or withdrawing certifications.

6. Defend your certification

Obtaining CMMC compliance isn’t enough. Regular cybersecurity assessments are necessary to defend your certification status.  

Besides mandatory audits (annually for CMMC Level 1 and triennially for CMMC Levels 2 and 3), more frequent evaluations can help uncover and seal security weaknesses before they escalate into significant breaches.  

CMMC Adoption: Beyond a Regulatory Requirement

Adopting the Cybersecurity Maturity Model is a regulatory imperative. Beginning December 16, 2024, any company aspiring to do business with the US Department of Defense will be obligated to fulfill the relevant cybersecurity controls in their CMMC maturity levels.  

However, CMMC compliance isn’t merely a question of claiming a spot in the DoD’s good books. Noncompliant contractors will run the risk of getting their active tenders terminated and incurring direct penalties like fines and imprisonment.  

Even if you’re not necessarily angling for defense contracts, pursuing CMMC certification can help bolster your cybersecurity posture and guard against unforeseen risks in your supply chain.