With the Cybersecurity Maturity Model Certification (CMMC) 2.0 finally unveiled on October 15, 2024, and duly operationalized sixty days later, many defense suppliers wonder if compliance is a priority concern.  

Some contractors would rather defer this step to a later date. Others prefer to skip it altogether.  

After all, what could possibly go wrong?  

Well, frankly speaking, a lot.  

Complying with the CMMC 2.0 framework is a significant step towards securing the Defense Industrial Base (DIB) supply chain from unforeseen cyber-attacks. It minimizes incidents that could compromise critical defense infrastructures and, by extension, jeopardize national security.  

And contrary to popular misconception, adhering to CMMC requirements doesn’t only benefit the Department of Defense (DoD). DIB organizations can equally leverage routine CMMC assessments to improve their cybersecurity posture.  

Besides, there are financial and reputational benefits to accrue by obtaining full CMMC certification.  

The first step in pursuing CMMC compliance is scheduling cybersecurity assessments. Such audits may be undertaken internally or led by third-party organizations, depending on your CMMC maturity level.  

Wondering if CMMC assessments are necessary at all? Let’s find out by unpacking the lessons learned by real-world defense contractors.  

1. FCI and CUI Aren’t One And The Same

The Cybersecurity Maturity Model Certification framework targets two primary classes of sensitive information. They include Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).  

Even if you’re not a cybersecurity expert, understanding the distinction between FCI and CUI is paramount. That’s because any CMMC assessment will typically start by scoping your organization for the presence of the two information classes.  

Both Federal Contract Information and Controlled Unclassified Information are generated by, for, or on behalf of the federal government. Besides, they’re typically included in defense tenders.  

The difference is that FCI entails non-public information. It encompasses things like payment details, sketch maps of military installations, architectural designs of defense offices, etc.  

Meanwhile, CUI is a broader category of sensitive but non-classified information. It typically requires higher protection levels than FCI.

2. Maturity Levels Are No Longer Five

CMMC 1.0 had five maturity levels. But to streamline the compliance process, the DoD condensed those into three levels in CMMC 2.0.  

It’s prudent to familiarize yourself with all three CMMC maturity levels before scheduling an assessment. The principal idea is to understand which level applies to your organization, as well as the specific information classes they target. 

Level 1

Level 1 is CMMC 2.0’s foundational level, which targets businesses that handle Federal Contract Information. It requires full implementation of 17 cybersecurity protocols derived from Federal Acquisitions Regulation (FAR) 52.204-21.  

If your business only handles FCI, you don’t require third-party-led assessments.  

However, you must conduct internal audits and report your compliance status to the DoD’s Supplier Performance Risk System (SPRS) annually. 

Level 2

CMMC Level 2, also known as advance level, is the most diverse. Most DIBs fall under this category.  

Level 2 applies to contractors that handle Controlled Unclassified Information. It mandates compliance with 110 cybersecurity requirements outlined in the National Institute of Standards and Technology (NIST) 800-171.  

Unlike Level 1 businesses that can self-audit, contractors seeking Level 2 assessments should enlist the services of CMMC third-party assessor organizations (C3PAOs).  

There’s a limited provision for self-assessments at Level 2 for certain businesses. However, these are highly exceptional circumstances that only happen at the contracting officer’s discretion. Further, the DoD requires triennial audits for Level 2 contractors.  

Level 3

Level 3 is the most advanced CMMC maturity level. It targets contractors that handle high-sensitive CUI, and seeks to safeguard the defense supply chain against Advanced Persistent Threats (APTs).  

To audit at Level 3, your organization must implement all Level 2 controls in addition to 24 protocols based on NIST 800-172.  

Like Level 2, Level 3 mandates triennial assessments. The audits must be spearheaded by an official from the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).  

3. Compliance Is Not Optional

Right from CMMC’s inception, compliance has always been mandatory for defense contractors. And while the CMMC 2.0 offers higher flexibility in terms of auditing oversight, there are stringent penalties for vendors that fall short.  

Non-compliant contractors may lose their tenders and be barred from future bids. This could result in devastating financial losses, especially for smaller businesses.  

For those aspiring for DoD contracts, evidence of full CMMC compliance is a fundamental eligibility criterion.  

Businesses that skimp on CMMC assessments may also suffer irreparable reputational damage.  

4. Assessments Are Already Underway

CFR 32, the rule that legally establishes CMMC 2.0, became operational in December 2024, and assessments began on January 31, 2025.  

According to the DoD, compliance will be mandatory for select contracts by mid-2025. Such contracts will further be required to achieve full CMMC implementation from October 2025.  

All other vendors will have another year to become duly compliant or risk losing their contracts.  

Here’s a summary of the phased compliance timeline; 

• October 15, 2024: The DoD publishes CMMC 2.0’s final rule 
• December 16, 2024: CFR 32 takes effect 
• Q1 of 2025: CMMC requirements start to appear on select solicitations 
• Q3 of 2025: Full implementation required for select contracts, including new awards and renewals 
• October 1, 2026: Certification requirements for all organizations handling FCI or CUI 

Evidently, CMMC assessments are already underway. Defense contractors that skimp on this critical process will only have themselves to blame.

5. Beware Of the 7012 Clause in Your Contracts

The 110 cybersecurity controls under CMMC Level 2 don’t only apply to defense suppliers. They’re a mandatory requirement for all contracts with a DFARS 7012 clause.  

Even if you’re unsure if your business handles FCI or CUI, the mere appearance of the 7012 clause on your tender awards is a valid call to action.  

This only underscores the imperative of conducting early CMMC assessments as the first step towards full cybersecurity compliance. 

6. Assessment Is Not an Overnight Event

CMMC audits are a time-intensive process. The assessment period can range from a few days to several weeks, depending on certain factors.  

Level 1 assessments are typically the fastest. That’s understandable, as this maturity level requires implementing basic cybersecurity protocols.  

Level 2 audits are way more intense, with Level 3 requiring the most rigorous assessments.  

In view of the fast-approaching compliance deadline, non-compliant defense contractors should schedule CMMC evaluations as a matter of priority.   

7. Assessments Are Capital-Intensive Too

CMMC assessments don’t come cheap. And just like the timelines, audit costs vary depending on the CMMC maturity level that applies to your business.  

Costs can range from $20,000 for Level 1 evaluations to well over $500,000 for Level 3 assessments.  

Factors like your organization’s size and the nature of your business will also determine how much you pay in assessment costs.  

Fortunately, you can manage CMMC assessment and certification costs by undertaking internal audits regularly. Routine evaluations let you seal any weaknesses and update your cybersecurity documents ahead of mandatory assessments. 

8. Mock Audits Are Anything But a Mockery

Mock assessments are critical when scheduling CMMC regulatory assessments. As mentioned, they let you scope your organization for security gaps and remediate these weaknesses proactively.  

Even if no major threats turn up during mock audits, you can leverage these evaluations to better understand your cybersecurity posture.  

Another exciting thing about mock assessments is that they’re less costly and don’t necessarily require an external team.  

However, it’s best to enlist an independent auditor for a balanced and objective audit.

9. C3PAOs Are Fewer Than You Think

As of mid-2025, there were an estimated 80 authorized C3PAOs on the CMMC Accreditation Body (CMMC AB). That number pales in comparison to approximately 80,000 defense contractors expected to obtain Level 2 certifications by Quarter 4 of 2026.  

Worse yet, many available C3PAOs are fully booked into 2026, and certifications must be renewed triennially.  

It doesn’t help that there are thousands of businesses aspiring to join the vast defense industrial base.  

In view of the limited number of accredited C3PAOs, now is the best time to join the queue. Hopefully, the line moves fast enough before the compliance deadline beckons. 

10. Your Stakeholders Require Assessments Too

CMMC 2.0 mandates assessment and certification for all defense organizations that handle FCI or CUI. That includes Managed Security Service Providers (MSSPs).  

If your company is already in a contractual agreement with an MSP, ensure the organization meets all the CMMC requirements under their respective maturity levels.  

The agency should schedule its own assessments and provide evidence of certification. Otherwise, you may have to incur additional costs for funding a separate CMMC assessment.

11. Proper Documentation Is Key

Each CMMC assessment culminates in the revision of cybersecurity documents, including a; 

• System Security Plan (SSP), which outlines your organization’s information architecture and how it aligns with CMMC requirements 
• Plan of Action and Milestones (POA&Ms), which spell out the roadmap for remediating security gaps uncovered during the previous audit 

Whether you conducted a mock or live audit, it’s important to update your documents accordingly.  

If you’re planning your maiden CMMC assessment, you may need basic templates of both documents to understand their key components. 

Tapping Into Real-Life CMMC Lessons to Streamline Your Compliance Roadmap

Scheduling CMMC assessments is a significant step towards obtaining compliance.  

While CMMC 2.0 was condensed into fewer maturity levels, each stage stipulates various requirements when undertaking cybersecurity audits. Knowing what applies to your company is critical before embarking on your compliance journey.  

Better yet, you can skip all the noise by tapping into real-life experiences of those who’ve been there and done that.  

Note that the cybersecurity landscape is constantly evolving. Therefore, keep abreast of emerging CMMC news and implement new reforms accordingly. Pay particular attention to any changes in CMMC assessment requirements, as such changes will significantly impact your ability to obtain full certification.