After operationalizing the Cybersecurity Maturity Model Certification (CMMC) 2.0 program on December 16, 2024, CMMC audits became a priority for any defense contractor.
Assessment is the first step towards CMMC certification. And duly compliant suppliers get to enjoy a host of financial and strategic benefits.
Obtaining CMMC certification provides unhindered access to the Department of Defense (DoD) tenders. Besides, it enables you to better understand your cybersecurity posture and strengthen any identified weaknesses.
One way to implement the CMMC framework is by understanding the rookie mistakes many contractors make en route to compliance. In this article, we highlight seven such missteps and how to prevent them.
1. Skimping On Compliance
Although CMMC is already operational, it’s surprising that many Defense Industrial Base (DIB) companies do not prioritize compliance.
Unfortunately, the DoD mandates all its vendors to adopt the CMMC framework. From contractors to subcontractors and even external service providers (ESPs), everyone must fulfil the minimum cybersecurity requirements under their maturity levels to obtain full certification.
Note that assessments began on January 2, 2025. And by November 10, 2025, CMMC requirements will start appearing in select DoD solicitations and awards.
More concerning is that, as at August 2025, there were roughly 80 fully authorized CMMC third-party assessment organizations (C3PAOs) against thousands of DIBs expected to seek Level 2 assessments. The more you wait, the longer the waiting queue gets.
2. Confusing Between FCI and CUI
Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) are two classes of sensitive information in defense contracts.
FCI is non-public. It includes information like maps, sketches, or blueprints of military installations.
Meanwhile, CUI is a broader category comprising higher-sensitive but unclassified information. Examples include military contracts, performance appraisal reports, financial reports, etc.
The core difference between FCI and CUI is that FCI is a subset of CUI.
Contractors that only handle FCI constitute the foundational CMMC maturity level – Level 1. This level requires implementing basic cybersecurity requirements which map to 17 controls in the Federal Acquisitions Regulation (FAR) 52.204-21.
If there’s CUI in your information storage assets, you’ll require Level 2 or 3 certifications.
Level 2 contractors must implement 110 controls derived from the National Institute of Standards and Technology (NIST) 800-171.
Level 3, which is the most sophisticated, deals with high-priority CUI. It mandates adopting all Level 2 controls plus 24 extra requirements based on NIST 800-172.
3. Misinterpreting Shared Responsibility Models in the Cloud
Cloud service providers (CSPs) and managed security service providers (MSSPs) are critical parts of the DIB ecosystem.
Therefore, it’s intuitive to imagine that having contractual engagements with these entities automatically makes you CMMC compliant.
But as mentioned, compliance is a personal undertaking. You’re within the CMMC scope, provided that you handle FCI or CUI.
4. Skipping Internal Gap Assessments
The DoD allows for annual self-affirmation of compliance for Level 1 businesses. For Level 2 and 3 contractors, audits are mandatory every three years.
A few Level 2 suppliers may self-assess, although most businesses in this category will require C3PAO-led audits. Level 3 assessments must strictly be undertaken by a Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)-appointed official.
Besides scheduling audits triennially, Level 2 and 3 businesses must also self-affirm their continued compliance annually.
Conducting internal gap assessments can streamline the DoD-mandated audits. It enables you to identify and seal potential security weaknesses ahead of the official evaluations. Besides, gap assessments can help you better understand your cybersecurity posture.
5. Lacking Proper Documentation
The best way to keep track of your company’s cybersecurity posture is by recording currently implemented cybersecurity controls in relevant policy documents, such as a System Security Plan (SSP).
Develop an SSP if you don’t already have one. Then, document all your cybersecurity policies, procedures, and controls.
Be sure to align the document with the CMMC requirements applicable to your maturity level.
Note that each cybersecurity audit should culminate in updating your policy documents.
6. Underallocating Resources
CMMC assessments are resource-intensive. A single audit can set you back thousands of dollars and take several months to complete.
Therefore, you must consider all relevant factors before allocating appropriate resources.
For instance, Levels 2 and 3 vendors must enlist third parties for their periodic assessments. That means you should research carefully to find a C3PAO or DIBCAC assessor that aligns with your budget.
Level 1 contractors without internal cybersecurity teams aren’t spared either.
Other key factors to consider when allocating CMMC assessment resources include;
- Need for employee training
- Number of gap assessments required
- Hardware and software upgrades
- Cost of ongoing cyber monitoring
- Incident report and remediation costs
7. Ignoring Supply Chain Risks
Congratulations for taking all precautions to avert threats in your systems!
But how certain are you that your stakeholders are pulling their weight to protect the supply chain?
As a general rule, ensure your CSP, MSSP, and other stakeholders with high-priority access to your information databases are CMMC compliant. The same yardstick would be applicable to your subcontractors.
Wrap Up
Avoiding these missteps not only inches you closer to full CMMC certification. It also enables you to maintain a robust threat monitoring system, protecting your information systems from unforeseen breaches.
Remember that active threat monitoring requires periodic cybersecurity audits. Whether you’re planning a regular assessment or a CMMC-mandated one, it pays to enlist a professional auditor.
Always insist on a duly credentialed C3PAO for all your cybersecurity audits. Choose an agency with years of practical experience auditing similar businesses, as verified by their previous clients.
