The CMMC Compliance Deadline is Here: Is it too late to become compliant?

 We have good news and bad news. The bad news (well, unfortunate news if you’ve procrastinated) is that the CMMC compliance deadline is here. The Cybersecurity Maturity Model Certification (CMMC) 2.0 final rule has been published and became effective on December 16, 2024. But is it too late to become compliant? 

Now for the good news (even if you’ve procrastinated): No, it is not too late to become compliant. However, you’ll need help from accredited CMMC Third-Party Assessor Organizations (C3PAOs) to pass the appropriate assessments.  

Because the Department of Defense (DoD) has made it clear: Starting in 2025, government contractors must achieve CMMC certification to maintain eligibility for DoD contracts. 

Failure to do so could result in contract termination, the inability to win new contracts, or the loss of contract renewals.  

Here is everything you need to know to make your organization compliant and poised to win new and retain DoD contracts. 

What is CMMC Compliance? 

CMMC 2.0 is the DoD’s compliance requirement for any organization that handles sensitive information about United States defense strategies. It is divided into two categories: Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). 

This is to ensure that the entire supply chain has airtight security. Because the moment one organization is at risk, so is the United States Department of Defense. That requires every contractor or subcontractor to implement and maintain the appropriate cybersecurity systems and compliance requirements. 

The 3 Levels of CMMC Compliance 

The CMMC split its requirements into three levels, depending on the sensitivity of the information your organization deals with.  

Level 1 - Foundational

Most organizations with DoD contracts should already have reached Level 1 compliance. This foundational level is all about the basic safeguarding of FCI by ensuring basic cyber hygiene practices are followed.  

Level 1 includes completing annual self-assessments and audits of the 15 fundamental security requirements outlined in FAR clause 52.204-21.  

All assessment results must be entered into the Supplier Performance Risk System (SPRS) for DoD review and monitoring.

Level 2 - Advanced

The Level 2 certification focuses on the broad protection of CUI.  
 
Organizations at this level can do a self-assessment but likely need to be assessed by a third-party (C3PAO) organization, depending on program requirements.  

Certification remains valid for three years from the certification date — with an annual affirmation of all 110 security requirements aligned with NIST SP 800-171 Revision 2.

Level 3 - Expert

The final certification includes a higher level of CUI protection against persistent threats.  

Organizations must undergo a mandatory Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) assessment every three years.  

To achieve Level 3, organizations must first obtain and maintain Level 2 certification and provide an annual affirmation verifying compliance with the 24 identified NIST SP 800-172 requirements. 

Our CMMC Implementation Checklist 

If you’re feeling the pressure of this deadline and aren’t sure where to start, use our 7-step checklist below to help get your organization in order. Keep in mind that you will still likely need help from your MSP or a C3PAO to ensure you are CMMC compliant. In most cases, you'll need both.  

But we’ve got a quick start for you to start getting up to speed and staying compliant: 

1. Conduct an information audit

Start by listing all of your organization's information systems, networks, and data types.  
 
This includes mapping out where Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) reside within your organization.  
 
Remember to include digital and physical assets in your inventory and third-party systems that interact with defense information. If you need help with this crucial first step, we can help. 

2. Choose the appropriate CMMC Level 

Next, identify the CMMC level you need to apply for based on your self-audit and contract requirements.  

Level 1 is suitable for organizations handling only FCI.  

Level 2 is required for CUI protection.  

Level 3 is for organizations managing critical CUI or facing advanced persistent threats.  

3. Self Assessment vs. Requirements 

Conduct a thorough gap analysis, comparing your current security practices against CMMC requirements for your chosen level.  

Our technology advisors can also help you identify gaps, pick your CMMC level, and find a C3PAO to help you become CMMC compliant. 

4. Partner with C3PAO 

For Levels 2 and 3, we recommend you partner with a C3PAO with experience in your industry and certification level.  

Ensure they're listed in the CMMC Marketplace and maintain proper accreditation through the CMMC Accreditation Body. 

5. Complete a System-wide Audit 

List the Plan of Action & Milestones (POA&M) you need to address identified gaps, noting that Level 1 doesn't permit POA&Ms.  

Develop a comprehensive System Security Plan (SSP) documenting your security controls, policies, and procedures.  

6. Address Gaps 

Implement necessary security controls and address gaps according to your POA&M. This may involve deploying new technologies, updating policies, conducting training, or revising procedures. Focus on high-priority items first, especially those affecting CUI protection. 

7. Maintain Compliance & Conduct Annual Assessments 

Establish a continuous monitoring program to maintain certification status. Conduct required annual affirmations and assessments based on your CMMC level. Regular internal audits help ensure ongoing compliance between formal assessments. 

Start Compliance Checks Today  

The CMMC 2.0 final rule is a significant update to the DoD and defense contractor relationships. Organizations need to meet the initial requirements and make an ongoing commitment to upholding those cybersecurity standards.  

Organizations handling DoD information must begin compliance efforts as soon as possible to meet certification deadlines and maintain contract eligibility. 

If you need help getting started identifying gaps in your current process, selecting your assessment levels or finding an experienced C3PAO, get in touch with one of our technology advisors today.