The Cybersecurity Maturity Model Certification (CMMC) is a critical requirement for any defense contractor working within the Defense Industrial Base (DIB). Introduced by the Department of Defense (DoD), CMMC ensures contractors have the necessary cybersecurity practices and protections in place to safeguard sensitive information, such as Controlled Unclassified Information (CUI).
What is CMMC compliance? It’s a framework that assesses and certifies your organization’s adherence to cybersecurity standards. And with the CMMC compliance deadline approaching, now is the time to act. This blog outlines the steps your organization needs to take to get ready.
Understand the CMMC Framework and Its Levels
Before diving into implementation, it’s essential to understand the CMMC framework. CMMC is structured around multiple levels of cybersecurity maturity, from foundational practices to advanced controls:
- CMMC Level 1: Basic cybersecurity hygiene
- CMMC Level 2: Intermediate practices, aligned with NIST SP 800-171
- CMMC Level 3: Advanced practices, aligned with NIST SP 800-172
Most defense contractors will need to achieve CMMC Level 2 certification to handle CUI and remain eligible for defense contracts.
Build Your CMMC Compliance Checklist
A detailed CMMC compliance checklist helps ensure your organization stays on track. Some of the key elements to include:
- Determine your required CMMC level based on the type of contracts you pursue.
- Conduct a gap analysis to compare your current cybersecurity posture to CMMC requirements.
- Develop or update your System Security Plan (SSP).
- Create a Plan of Action (POA) to resolve any identified gaps.
- Schedule your CMMC compliance audit or self-assessment.
Perform a Readiness Assessment
Start with a readiness assessment to evaluate your cybersecurity environment. Many companies choose to work with a consultant or use CMMC compliance software to simplify the process. A readiness assessment helps you:
- Identify weak points in your system.
- Map existing controls to required CMMC practices.
- Determine whether you need a third-party assessment from a Certified Third-Party Assessment Organization (C3PAO).
Align With NIST Guidelines
CMMC Level 2 requirements are closely aligned with NIST SP 800-171. Higher levels incorporate additional requirements from NIST SP 800-172 to defend against advanced persistent threats (APTs). Familiarize your team with these documents and evaluate your existing controls accordingly.
Working through these frameworks helps ensure your organization meets essential cybersecurity standards and mitigates vulnerabilities before an official CMMC compliance audit.
Create a System Security Plan (SSP)
The System Security Plan (SSP) is a living document that outlines how your organization addresses each required control. It includes:
- An inventory of your IT assets
- A breakdown of implemented security controls
- Descriptions of how your system protects CUI
This is one of the most important documents in your compliance journey. Without it, you won’t pass your CMMC audit or be deemed CMMC compliant.
Develop a Plan of Action and Milestones (POA&M)
Not every organization will be compliant from day one. That’s why the Plan of Action and Milestones (POA&M) is so valuable. This plan should:
- Outline existing gaps and areas of non-compliance
- Set target dates for resolving these issues
- Assign responsibility to specific team members
Creating a realistic POA&M demonstrates your commitment to achieving CMMC compliance, even if your organization is still maturing.
Invest in CMMC Compliance Software
CMMC compliance software streamlines the process by:
- Automating document collection
- Tracking progress toward compliance goals
- Providing templates for SSPs and POA&Ms
- Offering audit preparation tools
Software tools can help manage annual self-assessments, track real-time risks, and prepare for party assessment organizations (C3PAOs).
Train Your Team on Cybersecurity Practices
Your employees are the front line of defense against cyber threats. Include regular training in your compliance plan so your team understands:
- How to identify phishing and other attacks
- The importance of handling and protecting CUI
- Their role in maintaining cybersecurity controls
Well-trained staff help enforce policies and ensure you're ready when the CMMC compliance audit comes.
Perform a Mock Audit
A mock audit can help your organization gain a clear understanding of its readiness. This simulated assessment allows you to:
- Identify overlooked vulnerabilities
- Practice answering auditor questions
- Validate documentation and security controls
Consider having an external consultant conduct the mock audit to provide an unbiased evaluation.
Keep Up with CMMC Updates
CMMC 2.0 introduced important changes, including reduced certification levels and greater flexibility for smaller contractors. Staying informed about these updates is key to staying compliant.
Also watch for the final rule that will define the official timeline and enforcement details for the CMMC program.
Maintain Continuous Compliance
CMMC is not a one-and-done project. Compliance must be maintained over time with:
- Annual self assessments to check on control effectiveness
- Regular updates to your SSP and POA&M
- Ongoing monitoring of systems and risks
Make compliance part of your organizational culture to ensure long-term success.
The Bottom Line: Prepare Now, Win Later
Meeting CMMC requirements isn’t just about staying eligible for defense contracts; it’s about building a resilient, secure business. The stakes are high, but with a clear action plan, you can confidently move forward.
Start by building your CMMC compliance checklist, aligning with NIST standards, and adopting tools to simplify your path. Whether you're working toward CMMC Level 2 certification or beyond, these steps will position your business for long-term success.
By taking proactive steps today, you can achieve CMMC compliance and demonstrate your commitment to cybersecurity in the defense sector.