CMMC Compliance: Practical Steps for Concerned GovCons

Quick Links

⏰  CMMC Deadlines Start October 1, 2025
🏁  Timeframe for CMMC Readiness
🔬  The CMMC Assessment Process
🔑  Key Recommendations

Where does your organization stand on the path to CMMC readiness?

The first in a series of rolling deadlines is approaching, and some organizations still find this a surprisingly difficult question to answer.

The complexity of the regulation, the overwhelming volume of information, and the anxiety around failing the audit can easily obscure the practical steps that businesses should be taking now to achieve compliance. 

Let’s put aside fear and hype to look at the steps that GovCons should be taking now to proactively get ahead of the curve and ensure a smooth transition to compliance.

Demystifying CMMC Deadlines

Commitment to high standards of cybersecurity is a long-standing expectation for organizations operating within the U.S. defense supply chain. Navigating a litany of compliance requirements, including frameworks such as NIST, FIPS, and DFARS, among numerous others, is just the operational norm. 

The most recent addition to the DoD’s cybersecurity lexicon is the Cybersecurity Maturity Model Certification (CMMC). It’s the department’s strategic implementation of a comprehensive third-party verification layer to address cyber risk within the DIB and guarantee contractors’ implementation of mandated security controls.

CMMC assessments officially commenced in January 2025, preceding the first deadlines, which begin their phased rollout in October 2025 and continue through 2027.

For the benefit of key decision-makers, this section clarifies the CMMC deadlines in simple terms, cutting through complexity to reduce confusion and anxiety.

CMMC Deadline 1: October 1, 2025.

Effective on this date, CMMC requirements will become the standard in all new DoD contracts and task orders. This means that businesses intending to bid on or receive new DoD work (or subcontractors working with businesses that intend to do so) will need to pass an audit by a C3PAO to be considered.

Moreover, existing contracts undergoing renewal or significant modification on or after this date will also begin to require CMMC compliance. 

Organizations with static, long-term contracts not seeking new business or renewals will generally not be impacted by this first deadline.

CMMC Deadline 2: October 1, 2026.

Starting on this date, CMMC will apply to all active DoD contracts, including those that were in place before this deadline and haven’t undergone renewal or significant modification. Sometimes called “look back,” this deadline is aimed at bringing older, static contracts under the CMMC mandate.

This means that even if your current long-term contracts with the DoD weren’t subject to the 2025 deadline because they didn’t renew or change, October 1, 2026 is the absolute deadline to achieve compliance by undergoing a formal audit process (conducted by an accredited C3PAO) to maintain eligibility and continue performing on these existing agreements.

CMMC Deadline 3: October 1, 2027.

While the 2025 and 2026 deadlines phase in requirements based on contract events (new bids, renewals, existing contract inclusion), the 2027 deadline mandates CMMC as a fundamental qualification for being a DoD contractor handling sensitive information, irrespective of individual contract status. 

It signifies that CMMC certification becomes a baseline standard for simply participating in the DIB ecosystem going forward.

What’s a Realistic Timeframe for Achieving CMMC Readiness?

When discussing timelines, it’s important to clarify that we’re focusing here on timelines for CMMC Level 2 compliance, as opposed to Level 1 or Level 3. 

The reason is that CMMC Level 1 is a foundational standard that only requires the basic domains for safeguarding data, as described in CFR 52.204-21. GovCons can meet this standard on an ad hoc basis and achieve certification through an annual self-assessment.

Similarly, CMMC Level 3 only applies to companies that need to address advanced persistent threats that target CUI at high priority DoD programs. Because it only applies to only a small subset of GovCons that have already achieved Level 2 compliance, it’s also not a common stumbling block. 

As far as Level 2 compliance deadlines, despite what official CMMC documentation may suggest, initiating your preparation well in advance is imperative. 

Achieving CMMC compliance is a complex process that demands a substantial investment of time, which correlates with your organization’s current cybersecurity posture.

From our vantage point as an experienced Registered Provider Organization (RPO), we consistently see that, even for organizations with a high level of security maturity, reaching full readiness for a C3PAO audit requires at least 180 days following a domain control gap analysis.

From there, the Cyber-AB recommends a 90-day “cool down” period during which you gather records and evidence from your CMMC-ready systems to demonstrate effective compliance practices and adoption during your third-party assessment.

Again, that’s an average of 9 months for assessment prep even for businesses with buttoned-up cybersecurity controls.

Organizations with extensive gaps and absent controls face a dramatically longer remediation period that can extend past 18 months.

What Does the Assessment Process Look Like?

While each organization’s route to CMMC compliance is distinct, the journey nevertheless follows a predictable sequence of core phases. In this section, we will provide a general overview of the key steps involved in this typical certification pipeline.

Phase 1: Internal Readiness Check and Self-Assessment

The first step on your CMMC journey is taking a deep, honest look in the mirror by performing an internal self-assessment. Consider this your certification rehearsal, where the purpose is to bring your organization face-to-face with its current cybersecurity reality. 

A good reference material that you can use to guide this self-assessment is the guide provided by the DOD’s CIO, which is organized similarly, in terms of domains and controls, to the standards that RPOs and C3PAOs will use further down the assessment chain. 

How does an organization perform a self-assessment?

The same way a C3PAO would, by systematically evaluating where your existing posture and technical controls stand against CMMC requirements.

In practice, this involves:

• Clearly defining your scope, including all systems that process, store, or transmit FCI or CUI
• Meticulously reviewing your documentation (policies, procedures, system architecture blueprints)
• Conducting candid interviews with the people on the frontline.

The payoff comes in the form of a clear picture of your cyber maturity baseline. You’ll be positioned to pinpoint where your compliance gaps are hiding and gain a realistic understanding of the effort it’ll take to address them.

Phase 2: Engaging an RPO

Enlightened by the findings of their internal assessment, many organizations elect to enlist external support from an RPO to bridge gaps and shortcomings.

An RPO is a company validated by the Cyber-AB and authorized to deliver consulting and advisory services to help their clients pass the C3PAO audit.

RPOs possess domain expertise in the CMMC model and its foundation, the NIST 800-171 framework. 

The support of an RPO spans multiple areas, including facilitating a detailed understanding of specific requirements, providing an independent validation of the internal gap analysis, and offering guidance and assistance in developing mandatory documentation such as the System Security Plan (SSP).

RPOs serve as dedicated partners to support readiness and preparation. Their value lies in getting client organizations into peak condition. Although they don’t conduct the official CMMC assessment, they typically run mock assessments, a trial run done by an external party to gauge your readiness, in which an RPO pulls out 30 controls at random and performs a targeted assessment to help you measure your level of preparedness.

Phase 3: C3PAO and Formal Assessment

Having navigated the readiness steps, the next milestone is the official validation conducted by a CMMC Third-Party Assessment Organization (C3PAO). This is the point where all the time and energy spent on preparation are formally measured against the standard.

C3PAOs hold a specific accreditation from Cyber-AB, designating them as the sole entities authorized to perform the formal CMMC certification audits.

A certified CMMC assessor operating under the C3PAO’s authority will conduct a deep audit of your organization’s security landscape. This formal process is comprehensive, involving a detailed analysis of your security controls, a thorough review of all supporting documentation, and interviews with key personnel to confirm understanding and implementation. 

The objective is to gather the necessary evidence and provide an independent, certified determination of whether your organization’s cybersecurity posture aligns with the mandatory CMMC requirements.

Phase 4: Your Report Card: Pass, Fail, or POAM

If the audit confirms that your organization meets all CMMC requirements, the C3PAO sends its results to the Cyber-AB. Assuming all is well with the final inspection, an official certification is issued, and your compliant status is logged in the DoD’s SPRS system. 

Congratulations! Your organization is officially CMMC certified.

Conversely, if the assessment uncovers significant non-compliance, critical controls missing, or too many deficiencies overall, the C3PAO can’t recommend certification, essentially meaning you’ve failed the audit.  

More often, however, if the C3PAO finds that a company has only a small number of gaps and deficiencies that aren’t considered too egregious, you’ll be allowed to address the issue(s) via a Plan of Action & Milestones (POAM).

A POAM is your plan to fix specific security gaps and shortcomings. Within CMMC, this is an official document used to track deficiencies that weren’t remediated before the assessment but are deemed permissible for resolution within a defined post-assessment period. It’ll outline the exact steps, assigned personnel, and required resources, culminating in a hard deadline (usually 180 days) by which the issue must be fully addressed.

However, you MUST achieve a score of at least 88 on the assessment to be given the opportunity to remediate your POAMs. If you fail to achieve this score, or fail to meet critical areas of the CMMC assessment, you will be forced to begin the entire formal assessment process over again — a significant delay of several months.

Phase 5: Sustaining Compliance Through Annual Attestation

Achieving CMMC certification isn’t a one-and-done undertaking. Think of it less like graduating and more like committing to a fitness program. The real work isn’t achieving a cybersecure lifestyle but rather maintaining it.

To that end, the DoD requires CMMC-certified organizations to conduct and submit an annual self-attestation (sometimes called an affirmation) directly into the SPRS.

In essence, this is a formal declaration signed by a senior official confirming that the organization’s cybersecurity posture continues to meet CMMC standards between triennial C3PAO audits. 

Recommendations and Advice

Start by rigorously defining and documenting the scope of your CMMC readiness activities. If you find the DOD CIO guidance mentioned above overwhelming, we recommend asking your MSP for help with a preliminary assessment, or find an RPO that offers a summary self-assessment as a starting point.

As a word of caution, if you work with an MSP that is not also an RPO, you’re likely best served by finding one. In our experience, IT service providers not familiar with the intricacies of CMMC typically take far too long to support assessment prep and often suffer significant gaps in their readiness recommendations.

A precise and accurate readiness CMMC scope is foundational. It dictates exactly which systems, networks, processes, and personnel are subject to the standard. Poorly defining your scope can lead to either over-investing in irrelevant areas or, worse, failing the assessment because critical systems handling CUI were overlooked.

Start a dialogue with RPOs and C3PAOs as early as possible. Given the significant number of DoD contractors (200,000+) requiring certification and a finite number of accredited service providers (~500 RPOs for readiness and only ~65 C3PAOs for assessment!), capacity will become a major constraint. Engaging potential partners early helps avoid last-minute stress and potential delays.

Prioritize developing your System Security Plan (SSP) and associated documentation. The SSP is the cornerstone of your CMMC documentation, articulating how your organization meets each required control. This, along with policies, procedures, and evidence of implementation, is what assessors will analyze during the audit. Creating these documents is time-consuming and requires a deep understanding of CMMC. Starting early allows for thoroughness and iterative refinement before the audit.