Government & defense

CMMC 2.0 readiness assessment

A CMMC level has appeared in a solicitation you want, or your prime has asked for your SPRS score and the date of your certification. Readiness tells you which level you actually need, what belongs in scope and where you stand against every requirement, so you walk into your assessment with a System Security Plan that matches how you work and evidence an assessor can verify — and your senior official can affirm with confidence.

Formal outcome from
A C3PAO authorized by the Cyber AB (Level 2 certification) or the DoD’s DIBCAC (Level 3); Level 1 and some Level 2 contracts rely on your own self-assessment and affirmation
Who asks for it
DoD contracting officers · Prime contractors flowing down DFARS clauses
Our role
Readiness, documents and the Microsoft build — a C3PAO certifies
Next rollout date
November 10, 2026
Your organization — readiness viewEvery requirement, an owner and its evidence
Readiness
  • SCOPE
    Scope and system boundary
    Ready
  • RISK
    Risk assessment and register
    Ready
  • ACCESS
    Access reviews, with evidence
    Gap · owner set
  • CHANGE
    Change management
    Closing
  • VENDOR
    Vendor management
    Gap · owner set
  • TEST
    Penetration test evidence
    Report in hand
Handed to the assessor you choose — the opinion is theirs
Gaps found before the audit
Who it’s for

Why CMMC lands on your desk.

The Cybersecurity Maturity Model Certification program is how the Department of Defense verifies that the companies it works with actually protect the information it shares. The program rule, 32 CFR Part 170, is in effect, and the DFARS acquisition rule is now putting CMMC levels into contracts on a phased basis through DFARS 252.204-7021. Once a level appears in a solicitation, meeting it is a condition of award, and your status has to stay current in the Supplier Performance Risk System (SPRS) for as long as you hold the contract.

The level follows the information. If you only handle Federal Contract Information (FCI), Level 1 asks for the basic safeguarding requirements of FAR 52.204-21, an annual self-assessment and an annual affirmation in SPRS. If you handle Controlled Unclassified Information (CUI), Level 2 asks for all 110 requirements of NIST SP 800-171 Rev 2 — self-assessed for some contracts, and for most CUI work assessed by a Certified Third-Party Assessment Organization (C3PAO) authorized by the Cyber AB. Level 3, reserved for the most sensitive programs, adds selected requirements from NIST SP 800-172, is assessed by the DoD’s own Defense Industrial Base Cybersecurity Assessment Center (DIBCAC), and builds on a Level 2 certification you must already hold.

Teams come to readiness because a CMMC assessment is unforgiving. Assessors test every assessment objective in NIST SP 800-171A, not just the headline of each requirement. Only certain lower-weighted requirements may sit on a Plan of Action and Milestones (POA&M), conditional status depends on a minimum score and a close-out assessment, and a senior official signs an affirmation that carries real legal weight. A C3PAO can’t consult for a company it assesses, so the preparation has to come from someone on your side of the table — which is exactly where readiness sits.

Who asks for it
DoD contracting officersPrime contractors flowing down DFARS clausesYour senior affirming officialDefense program offices sharing CUIInvestors and acquirers in the defense industrial base

Subcontractors handed a flow-down

Your prime has asked for your SPRS score, your SSP and your target CMMC level. You need to know what your contracts genuinely require, and a credible path to it before the next award decision lands.

Primes and mid-tier suppliers

CUI moves through your engineering, manufacturing, program and finance teams. You’re accountable for your own certification and for the suppliers beneath you, and you need one scope everyone agrees on.

Companies new to defense work

You’ve won, or want to win, your first DoD contract. You need to understand FCI versus CUI, pick the right level and avoid building an expensive CUI environment the contract never called for.

Teams whose self-score won’t survive scrutiny

You posted a NIST SP 800-171 score some time ago. Now a C3PAO will test it objective by objective and a senior official will affirm it, so the number has to be true.

Packages

Find the gaps. Write it down. Build it in the Microsoft cloud.

Three defined packages, each with a clear scope and a clear set of deliverables, for defense contractors that hold CUI. Start with the one that matches where you are: you know exactly what you are buying, and every package ends with work your C3PAO can examine.

The gap assessment shows you what needs fixing. The SSP and POA&M put it on paper the way an assessor reads it. The Microsoft build closes the technical gaps where your CUI actually lives.

01

CMMC Level 2 gap assessment

Know exactly where you stand before anyone scores you.

For Contractors whose contracts name Level 2 and who need an honest answer to “are we ready?”

You get your environment measured against every Level 2 requirement and assessment objective, to the standard a C3PAO applies. Your CUI boundary is drawn, your score is calculated honestly, and every gap is ranked by its point value and whether the rule lets you defer it. It is the low-risk first step: you leave with a plan, not a sales pitch.

What you receive
  • A CUI scoping workshop and a boundary that follows the five asset categories
  • An objective-level gap assessment across all 110 requirements
  • An honest SPRS score under the DoD Assessment Methodology
  • Every gap ranked by point value and by whether a POA&M can cover it
  • A clear answer on whether you need GCC High, an enclave or neither
  • A remediation roadmap with an owner for every gap
  • A leadership briefing your senior official can act on
Helps closeCARA
Book a gap assessment

Usually leads to the SSP + POA&M package

02

SSP + POA&M package

The documents your assessor reads first, written from your real environment.

For Contractors with no System Security Plan, or one that describes a system that no longer exists.

Your System Security Plan is the first thing a C3PAO reads and the document every other finding is checked against. You get one written from your actual environment, with a statement for each of the 110 requirements, and a POA&M that stays inside what the rule lets you defer. Your cloud and managed providers’ responsibilities are mapped in, so nothing falls between you and them.

What you receive
  • A System Security Plan with an implementation statement for every requirement
  • A system description, boundary diagram and CUI data-flow diagrams
  • A POA&M limited to the items the rule allows, with an owner for each
  • Policies and procedures for all 14 requirement families
  • An incident response plan that covers your DFARS 252.204-7012 reporting duty
  • Your providers’ customer responsibility matrices mapped into your documents
  • An SPRS score worksheet that matches what the SSP says
Helps closeCAIRPSAT
Ask about SSP + POA&M

Usually leads to the GCC High / Azure Government build

03

GCC High / Azure Government build

A Microsoft environment your CUI can live in, built for the requirements.

For Contractors whose CUI sits in commercial Microsoft 365, consumer file sharing or servers that can’t meet the requirements.

Your Microsoft 365 GCC High tenant, Azure Government workloads or CUI enclave is built and configured by engineers who secure Azure and Microsoft 365 for a living. Identity, devices, data protection and logging are set up for the requirements an assessor tests and documented as evidence for your SSP, while your mail, files and Teams move across with access rebuilt around least privilege.

What you receive
  • Your GCC High tenant, Azure Government environment or CUI enclave, built and configured to fit your contracts
  • Identity built on Entra ID: Conditional Access, phishing-resistant MFA and controlled privileged access
  • Devices enrolled in Intune with hardened baselines and FIPS-validated encryption
  • CUI protected with Purview sensitivity labels and data loss prevention
  • Logging and alerting through Defender and Sentinel, with audit records kept and reviewed
  • Mail, files, SharePoint and Teams moved across, with each move planned around how your business works
  • Build documentation mapped to the requirements, ready to drop into your SSP
  • A handover so your team can run what was built
Helps closeACIAAUCMMPSCSI

Licenses for Microsoft 365 GCC High and Azure Government come from Microsoft or an authorized reseller, and Microsoft decides who is eligible. You get the environment designed, built, configured and documented.

Where CMMC stands

The rule is final. The dates are set.

CMMC is no longer a proposal. The program rule, 32 CFR Part 170, took effect on December 16, 2024, and set up the levels, the assessments and the ecosystem of assessors. The DFARS acquisition rule took effect on November 10, 2025, and gave contracting officers the clause, DFARS 252.204-7021, that puts a CMMC level into a solicitation and makes holding it a condition of award.

The DoD is bringing the requirement in over four rollout periods, each beginning on November 10. Each period widens what a solicitation can ask of you, ending in full implementation across every applicable contract, including option periods on work you already hold. Until then, the solicitation in front of you is what decides; the dates tell you when to expect each requirement to start appearing.

  1. In effect

    Self-assessments enter contracts

    Solicitations and contracts that call for CMMC can require Level 1 (Self) or Level 2 (Self) status as a condition of award. The DoD may, at its discretion, require Level 2 (C3PAO) instead of a self-assessment, and may apply the requirement when an option is exercised.

    32 CFR 170.3(e); DFARS 252.204-7021
  2. Next

    Third-party Level 2 certification

    On top of the first period, applicable solicitations can require Level 2 (C3PAO) status as a condition of award. The DoD may defer that requirement to an option period, and may call for Level 3 (DIBCAC) in its place.

    32 CFR 170.3(e); DFARS 252.204-7021
  3. Ahead

    Level 3 enters contracts

    Applicable solicitations can require Level 3 (DIBCAC) status as a condition of award, and Level 2 (C3PAO) status can be required before an option period is exercised on an existing contract.

    32 CFR 170.3(e); DFARS 252.204-7021
  4. Ahead

    Full implementation

    CMMC requirements are included in all applicable solicitations and contracts, including the exercise of option periods on contracts awarded before the rollout began.

    32 CFR 170.3(e); DFARS 252.204-7021
Which level

Three levels. The information decides.

Three levels, four kinds of assessment. The information you handle sets the level; the solicitation sets whether you assess yourself or face an independent assessor. The requirements below come straight from the rule.

Level 1 (Self)

15requirements
Information
Federal Contract Information (FCI)
Requirements
The 15 basic safeguarding requirements of FAR 52.204-21
Assessed by
You: a self-assessment entered in SPRS
How often
Self-assessment and affirmation every year
POA&M
Not allowed: every requirement must be met
Status
Final Level 1 (Self)

Level 2 (Self)

110requirements
Information
Controlled Unclassified Information (CUI)
Requirements
All 110 requirements of NIST SP 800-171 Rev 2
Assessed by
You: a self-assessment under the CMMC Level 2 Assessment Guide, scored in SPRS
How often
Triennial self-assessment; affirmation every year
POA&M
Allowed for limited, lower-weighted requirements, closed out inside the window the rule sets
Status
Conditional or Final Level 2 (Self)

Level 2 (C3PAO)

110requirements
Information
Controlled Unclassified Information (CUI)
Requirements
All 110 requirements of NIST SP 800-171 Rev 2
Assessed by
A C3PAO authorized by the Cyber AB
How often
Triennial certification assessment; affirmation every year
POA&M
Allowed for limited, lower-weighted requirements, closed out inside the window the rule sets
Status
Conditional or Final Level 2 (C3PAO)

Level 3 (DIBCAC)

134requirements
Information
CUI in programs the DoD identifies as highest priority
Requirements
The 110 Level 2 requirements plus 24 selected from NIST SP 800-172
Assessed by
The DoD’s DIBCAC, once you hold Final Level 2 (C3PAO) status for the same scope
How often
Triennial DIBCAC assessment; affirmation every year
POA&M
Allowed for limited requirements under the Level 3 rules, closed out inside the window the rule sets
Status
Conditional or Final Level 3 (DIBCAC)
Level finder

Which level fits you?

Answer three questions for a first read on where you land. Nothing you choose is stored or sent anywhere.

1 What information does the contract give you, or have you create?

FCI is contract information not intended for public release. CUI is information the government marks or identifies as needing safeguarding, such as controlled technical information.

2 Does a solicitation or your prime’s flow-down name an assessment type?

Answer if you handle CUI. Look for “Level 2 (Self)” or “Level 2 (C3PAO)” in the solicitation, or in DFARS 252.204-7021 as your prime flows it down.

3 Has the DoD identified the program for Level 3?

Answer if you handle CUI. Level 3 is reserved for the highest-priority programs, and the solicitation names it.

A starting point, not a determination. Your solicitation and contract decide the level and the assessment type; readiness puts that answer in writing for you.

Who certifies

We prepare you. Your assessor decides.

Formal outcome from

A C3PAO authorized by the Cyber AB (Level 2 certification) or the DoD’s DIBCAC (Level 3); Level 1 and some Level 2 contracts rely on your own self-assessment and affirmation

What they produce

A CMMC status — Final or Conditional — recorded in SPRS at the level your contract requires

Where readiness fits

Readiness is the work before the assessment: scoping, documentation, remediation and evidence. The certification decision belongs to the C3PAO or DIBCAC you face, and the affirmation belongs to your own senior official — never to the firm that helped you prepare.

32 CFR Part 170 (CMMC Program) 48 CFR / DFARS acquisition rule implementing CMMC DFARS 252.204-7021 DFARS 252.204-7012 FAR 52.204-21 NIST SP 800-171 Rev 2 NIST SP 800-171A NIST SP 800-172 and NIST SP 800-172A CMMC Assessment Guides and Scoping Guides (Levels 1–3) NIST SP 800-171 DoD Assessment Methodology DoD CIO guidance on FedRAMP Moderate equivalency 32 CFR Part 2002 (CUI Program)
Scoping

Draw the boundary before an assessor does.

Scope is the argument you make to an assessor about which parts of your company the assessment covers. Get it right and the assessment examines a system you understand and can evidence. Get it wrong and either the assessor widens it on the day, or you spend heavily protecting systems that never needed it.

At Level 2, the CMMC Scoping Guide sorts every asset into one of five categories. Each category is treated differently, and each comes with its own documentation an assessor expects to see.

CUI Assets

Assets that process, store or transmit CUI: the laptops, servers, file shares, cloud tenants, engineering tools and people that touch it.

What the assessor does
Assessed against every Level 2 requirement that applies to them.
The mistake we find
Leaving out the places CUI has drifted to: email attachments, personal drives, chat and collaboration tools, and the engineering workstation in the corner.

Security Protection Assets

Assets that provide security functions or capabilities to the CUI environment, whether or not they touch CUI: identity providers, firewalls, logging and monitoring platforms, and the people and providers who run them.

What the assessor does
Assessed against the Level 2 requirements relevant to the security capability they provide.
The mistake we find
Forgetting that a managed service provider’s remote management tools and a security operations provider’s monitoring platform belong in scope.

Contractor Risk Managed Assets

Assets that can, but are not intended to, process, store or transmit CUI, because of the security policies, procedures and practices you have in place.

What the assessor does
Documented in the asset inventory, the SSP and the network diagram, and reviewed by the assessor. If the documentation does not show adequate controls, the assessor can examine them like CUI Assets.
The mistake we find
Labelling an asset contractor risk managed without the policy, the technical control and the evidence that actually keep CUI off it.

Specialized Assets

Assets that may handle CUI but cannot be fully secured: Internet of Things and operational technology devices, government-furnished equipment, restricted information systems and test equipment.

What the assessor does
Documented in the inventory, the SSP and the network diagram, and managed under your risk-based policies rather than assessed against every requirement.
The mistake we find
Leaving shop-floor machines, test benches and lab equipment out of the inventory altogether.

Out-of-Scope Assets

Assets that cannot process, store or transmit CUI and provide no security protection to CUI Assets.

What the assessor does
Not assessed, provided the separation from CUI Assets is real and the assessor accepts your reasoning.
The mistake we find
Declaring a network segment out of scope when it shares credentials, management tools or network paths with the CUI environment.

An enclave: a smaller boundary, on purpose

An enclave is a deliberately narrow environment, on premises or in a government cloud tenant, where CUI lives and nowhere else. Only the people and systems that need CUI reach it, and everything outside it becomes out of scope or contractor risk managed, with the evidence to show why.

An enclave trades breadth for discipline. Fewer assets are assessed, but the boundary has to hold: separate identities or strong conditional access, controlled data transfer in and out, and no quiet copies of CUI back on the corporate network. For a company where CUI touches a few teams, it can shrink both the assessment and the cost of meeting it. For a company where CUI is everywhere, it can mean rebuilding how people work.

Readiness weighs the options against your contracts, your data flows and your people, and gives you a boundary you can defend before you build it.

The 14 families

110 requirements. Every objective tested.

Level 2 holds you to 110 requirements in 14 families. An assessor tests each one against the assessment objectives in NIST SP 800-171A, and a requirement is met only when every objective behind it is.

AC22 requirements

Access Control

Who and what can reach CUI, from where, and with what privileges.

Readiness reviews
Account management, least privilege, separation of duties, remote, wireless and mobile access, and how CUI flows between systems.
Often found
Shared administrator accounts, and remote access that skips the controls applied in the office.
AT3 requirements

Awareness & Training

People who handle CUI knowing the risks and their duties.

Readiness reviews
Role-based security training, insider-threat awareness and the records that show who completed what.
Often found
Generic training with nothing about CUI and no record of who took it.
AU9 requirements

Audit & Accountability

A trail of who did what on the systems that hold CUI.

Readiness reviews
Which events are logged, how logs are retained, reviewed and correlated, and who can alter them.
Often found
Logs collected and never reviewed, correlated or tied to an alert.
CM9 requirements

Configuration Management

Systems built and kept in a known, hardened state.

Readiness reviews
Baseline configurations, change control, least functionality, software restrictions and the inventory behind them.
Often found
No documented baseline, so no way to show drift from it.
IA11 requirements

Identification & Authentication

Proof of identity for every user, process and device.

Readiness reviews
Multifactor authentication, replay-resistant authentication, password rules and identifier management.
Often found
Multifactor authentication on remote access but not on privileged or network access for every user.
IR3 requirements

Incident Response

Detecting, reporting and recovering from incidents.

Readiness reviews
The incident-handling capability, how it is tested and the reporting path DFARS 252.204-7012 requires.
Often found
A plan nobody has exercised, and no DoD-approved certificate to report an incident with.
MA6 requirements

Maintenance

Maintenance that does not become a way in.

Readiness reviews
Control of maintenance tools, remote maintenance sessions, supervision of outside technicians and sanitizing equipment that leaves.
Often found
Vendors with unsupervised remote maintenance access to CUI systems.
MP9 requirements

Media Protection

CUI on paper, drives and removable media.

Readiness reviews
Marking, storage, transport, encryption of portable media and sanitization before disposal or reuse.
Often found
USB drives in daily use with no control over what is copied to them.
PS2 requirements

Personnel Security

Trust in the people given access to CUI.

Readiness reviews
Screening before access, and removing access when people leave or change roles.
Often found
Accounts that outlive the employment of the people who held them.
PE6 requirements

Physical Protection

Physical access to systems and to CUI itself.

Readiness reviews
Authorized access lists, visitor escort and logs, physical access devices and safeguards at alternate work sites.
Often found
Home offices handling CUI with no alternate-site safeguards on record.
RA3 requirements

Risk Assessment

Knowing your risks and the vulnerabilities behind them.

Readiness reviews
Periodic risk assessment, vulnerability scanning and remediation by risk.
Often found
Scans run without credentials, and findings never tracked to closure.
CA4 requirements

Security Assessment

Checking your own controls, planning the fixes and documenting the system.

Readiness reviews
Periodic control assessments, plans of action, ongoing monitoring and the System Security Plan itself.
Often found
An SSP that describes a system that no longer exists.
SC16 requirements

System & Communications Protection

CUI in transit and at the boundary.

Readiness reviews
Boundary protection, segmentation, FIPS-validated encryption, session controls, split tunneling and collaborative devices.
Often found
Encryption that is strong but not FIPS-validated.
SI7 requirements

System & Information Integrity

Finding and fixing flaws and malicious code.

Readiness reviews
Patching, malicious code protection, security alerts and monitoring for attacks and unauthorized use.
Often found
Patching tracked for servers and forgotten on engineering workstations.
Scoring and status

The score decides your status.

Every Level 2 assessment, self or C3PAO, produces a score under the NIST SP 800-171 DoD Assessment Methodology. You start at 110, one point for each requirement, and subtract a weighted value for each requirement not met: 5, 3 or 1 point, depending on how much harm leaving it open could do. Because the heaviest requirements carry 5 points, a score can fall far below zero.

The score is entered in SPRS and decides your status. Final status means every requirement is met. Conditional status means you reached the minimum score the rule sets and every open item is one the rule allows on a POA&M. Conditional status lasts only for the close-out window the rule sets, so it is a bridge, not a destination.

Starting score
110 points: one for each NIST SP 800-171 Rev 2 requirement.
Deductions
5, 3 or 1 point for each requirement not met, as the DoD Assessment Methodology sets. A few requirements earn partial credit, such as multifactor authentication in place for some users but not all.
Lowest possible score
−203, when no requirement is met.
Conditional Level 2 status
A score of at least 88 of 110, with every open requirement eligible for a POA&M.
What cannot sit on a POA&M
Any requirement worth more than 1 point, except encryption that is in place but not FIPS-validated (SC.L2-3.13.11), which the rule lets you defer; and a short list the rule excludes, among them the System Security Plan (CA.L2-3.12.4) and several access-control and physical-protection requirements carried over from Level 1.
Close-out
A POA&M close-out assessment, by the same kind of assessor as the original, confirms the open items are met. Pass it inside the window the rule sets and status becomes Final; miss it and Conditional status expires.
Level 1
No POA&M at all: each of the 15 requirements must be met before the affirmation.
Your status in SPRS
Recorded against a CMMC Unique Identifier that contracting officers and primes use to confirm your status before award.
Example

Example: a Level 2 score, worked through

A sample set of open requirements, not a client. Weights are from the DoD Assessment Methodology.

Starting score110
IA.L2-3.5.3Multifactor authenticationClose before assessment
−3

Partial credit: in place for remote and privileged access, missing for general network access. Worth more than 1 point, so it has to be closed before the assessment.

SC.L2-3.13.11FIPS-validated cryptographyPOA&M allowed
−3

Encryption is in place but its modules are not FIPS-validated. This is the one higher-weighted gap the rule lets you defer.

AC.L2-3.1.10Session lockPOA&M allowed
−1

A 1-point requirement, eligible for a POA&M.

AC.L2-3.1.11Session terminationPOA&M allowed
−1

A 1-point requirement, eligible for a POA&M.

PE.L2-3.10.6Alternate work sitesPOA&M allowed
−1

A 1-point requirement, eligible for a POA&M.

Score101

Score: 101 of 110. That clears the 88 minimum, yet Conditional status is out of reach while multifactor authentication for general users stays open, because it is worth more than 1 point. Close it before the assessment and the remaining four items can sit on a POA&M: the result is Conditional status, which becomes Final once a close-out assessment confirms them.

Providers and cloud

Cloud, MSPs and other service providers

Few defense contractors run everything themselves. Cloud services, managed service providers and security operations providers all touch the CUI environment, and CMMC treats each according to what it does for you.

The question an assessor asks is simple: for each requirement, who meets it, and where is the proof? Readiness answers it before the assessment, provider by provider.

Cloud services that hold CUI

A cloud service provider that stores, processes or transmits CUI for you must be FedRAMP Moderate authorized, or meet FedRAMP Moderate equivalency as the DoD CIO defines it, with the body of evidence that definition calls for.

MSPs and MSSPs

A provider that delivers security functions to your CUI environment is in scope as a Security Protection Asset. Its tools, people and access are examined as part of your assessment, against the requirements relevant to what it provides.

Other external service providers

Providers that are not cloud service providers do not need a CMMC status of their own to support you; they are assessed within your scope instead, so their practices become your evidence.

Customer responsibility matrix

A customer responsibility matrix records which requirements each provider meets, which you meet and which you share. Assessors ask for it, and it has to agree with the provider’s own documentation.

Export-controlled data

ITAR and EAR data add limits on who may access it and where it may be stored and supported. The cloud tier and support model you choose have to satisfy those rules as well as CMMC.

Incident reporting

DFARS 252.204-7012 requires rapid reporting of cyber incidents to the DoD through DIBNet, which needs a DoD-approved medium assurance certificate, along with preserving images of affected systems and submitting malicious software. Your providers’ contracts have to support that duty.

The affirmation

The affirmation behind your status

Every CMMC status carries an affirmation: a statement, entered in SPRS by a senior official of your company, that you meet the requirements of the level you claim and will keep meeting them.

An affirmation is a representation to the government. The Department of Justice’s Civil Cyber-Fraud Initiative uses the False Claims Act against contractors that misrepresent their cybersecurity, so an affirmation made on reassurance rather than evidence is a legal exposure for the company and for the person who signs.

Who affirms

An affirming official: a senior-level representative of your company who is responsible for ensuring compliance with CMMC requirements and has the authority to affirm continuing compliance.

At each assessment

When your self-assessment or certification assessment results are recorded, alongside the score.

Every year after

An annual affirmation of continuing compliance, at every level, for as long as the status is needed.

After POA&M close-out

When a close-out assessment confirms the open items are met and status moves from Conditional to Final.

What it rests on

Evidence an assessor would accept: a current SSP, an inventory that matches the network, logs that are reviewed and records that show controls operating. Readiness gives your official that record, and affirmation upkeep keeps it current.

What it covers

What CMMC readiness covers.

  • Level determination: FCI versus CUI, the DFARS clauses in your contracts and the assessment type your solicitations name
  • CUI identification against the NARA CUI Registry, including controlled technical information and export-controlled data you receive or create
  • Assessment scoping by asset category: CUI Assets, Security Protection Assets, Contractor Risk Managed Assets, Specialized Assets and Out-of-Scope Assets
  • Enclave options that shrink the boundary to the people and systems that truly need CUI
  • Gap assessment against all 110 NIST SP 800-171 Rev 2 requirements, tested at the level of the NIST SP 800-171A assessment objectives
  • The FAR 52.204-21 basic safeguarding requirements for Level 1
  • A System Security Plan that describes how each requirement is met in your actual environment
  • POA&M strategy that respects the rule’s limits on which requirements can be deferred and how conditional status is closed out
  • SPRS scoring under the DoD Assessment Methodology, with the weight of each open requirement made visible
  • External service providers and cloud: FedRAMP Moderate authorized or equivalent services, MSP and MSSP responsibilities, and a shared responsibility matrix
  • FIPS-validated cryptography, multifactor authentication, audit logging and the DFARS 252.204-7012 incident reporting duty
  • Policies, procedures and the evidence trail an assessor requests for each objective
  • Level 3 preparation against the selected NIST SP 800-172 enhanced requirements
  • Affirmation readiness: what your senior official is attesting to, and the records that support it
Engagements

CMMC readiness, sized to where you are.

The three packages above are the natural way in. Some of these engagements cover the same ground as one combined readiness engagement; others fit particular situations — Level 1 only, a self-assessment, a Level 3 path, a supplier base, a POA&M to close or an affirmation to keep current — and all of it is the work a C3PAO is not allowed to do for you. Every one ends with documents you keep and evidence you can show.

Contractors that handle FCI only

Level 1 readiness

Confirm that Level 1 really is your level, then meet and evidence every FAR 52.204-21 requirement before your senior official signs.

You receive
  • A written FCI-versus-CUI determination for your contracts
  • A review of each requirement against the Level 1 assessment objectives
  • A remediation list for anything not yet met
  • An evidence pack and affirmation support for your annual SPRS entry
Book a call about this
CUI holders whose contracts name Level 2 (Self)

Level 2 readiness for a self-assessment

Score yourself to the standard a C3PAO would apply, so the number you post and the affirmation behind it hold up if the DoD ever checks.

You receive
  • An objective-level gap assessment across all 110 requirements
  • A System Security Plan written from your environment
  • An SPRS score worksheet under the DoD Assessment Methodology
  • A POA&M limited to what the rule lets you defer
Book a call about this
Contractors whose solicitations or primes require Level 2 (C3PAO)

Level 2 readiness for a C3PAO certification assessment

Walk into your certification assessment with a defensible scope, an SSP that matches reality and evidence mapped to every assessment objective.

You receive
  • A scoping diagram and an asset inventory sorted by CMMC asset category
  • An objective-level gap assessment and a prioritized remediation roadmap
  • The SSP, policies and procedures the assessment examines
  • An evidence map from each objective to its artifact
  • Interview preparation for the people a C3PAO will speak with
Book a call about this
Contractors on programs the DoD identifies for Level 3

Level 3 readiness

Meet the 24 enhanced requirements selected from NIST SP 800-172 on top of a Level 2 environment that holds Final C3PAO status for the same scope.

You receive
  • A gap assessment against the selected NIST SP 800-172 requirements
  • Alignment of your Level 2 scope with the Level 3 boundary
  • The threat-informed documentation the enhanced requirements call for
  • An evidence map for the objectives DIBCAC assesses
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Companies whose CUI has spread, or who are weighing an enclave

CUI scoping and enclave review

Find where CUI actually lives, decide where it should live and draw a boundary you can defend to an assessor.

You receive
  • A CUI data-flow map across email, file shares, engineering tools and suppliers
  • An asset inventory sorted into the five CMMC categories, with the reasoning for each
  • Enclave options compared against your contracts, your people and the cost of change
  • A boundary diagram ready for your SSP
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Teams that believe they are ready and want to be sure before the assessor arrives

Pre-assessment readiness review

An independent look at every assessment objective, the way an assessor would examine, interview and test, so nothing on assessment day is a surprise.

You receive
  • Objective-by-objective readiness findings
  • A document and evidence review against the CMMC Assessment Guide
  • Interview rehearsal with the people who will be questioned
  • A list of what must close before the assessment and what may sit on a POA&M
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Contractors holding Conditional status

POA&M close-out readiness

Close every open item on your POA&M with evidence a close-out assessment will accept, before Conditional status runs out.

You receive
  • A review of each open item and its remediation
  • Evidence for each requirement you close
  • An updated SSP and score worksheet
  • Affirmation support for the move to Final status
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Primes and mid-tier suppliers accountable for the companies beneath them

Supplier readiness for primes

Know which suppliers receive FCI or CUI, which level each one needs and whether their SPRS status supports the work you plan to flow down.

You receive
  • A flow-down map of DFARS clauses and CMMC levels by supplier
  • A supplier questionnaire and a review of SPRS status and SSP summaries
  • A view of the suppliers who are not ready, with the options open to you
  • Guidance you can share with suppliers on what you expect of them
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Contractors with a CMMC status to keep

Affirmation upkeep

Keep the record behind each annual affirmation current as people, systems and providers change.

You receive
  • An annual evidence refresh against every requirement in scope
  • A change review of new systems, providers and CUI flows
  • An updated SSP, inventory and score worksheet
  • A briefing for your affirming official before each affirmation
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What you receive

What you have in hand when readiness is done.

1

Level and scope determination

A written conclusion on which CMMC level and assessment type apply to you, tied to the information you handle and the clauses in your contracts and solicitations.

2

Scoping diagram and asset inventory

A boundary diagram and an asset inventory sorted into the CMMC asset categories, with the reasoning for each — the scoping argument you’ll put in front of an assessor.

3

Objective-level gap assessment

Every requirement and assessment objective marked met, not met or partially met, with the evidence you have, the evidence you lack and what closing each gap involves.

4

System Security Plan

An SSP written from your real environment: system description, boundary, roles, and an implementation statement for every requirement in scope.

5

SPRS score worksheet

Your score under the DoD Assessment Methodology, requirement by requirement, so the number you post and the number an assessor reaches are the same number.

6

Remediation roadmap and POA&M

Prioritized remediation that closes the high-weight requirements first, plus a POA&M that only defers what the rule lets you defer.

7

Policies and procedures

Policies and procedures for the requirement families that need them, written to match how your people actually work rather than a generic template.

8

Service provider responsibility matrix

A matrix showing which requirements your cloud providers, MSP and other external service providers meet, which you meet, and the documentation that proves it.

9

Evidence map and assessment-day readiness review

An index pointing each assessment objective to its artifact, and a walk-through with the people an assessor will interview so they know what will be asked of them.

Common gaps

What a CMMC readiness review tends to surface.

Better found now, by people on your side, than by your assessor.

CUI that has spread to email, file shares, laptops and engineering tools well beyond the system everyone believes is in scope

An SSP written from a template that describes controls nobody operates

Cloud services storing or processing CUI that are neither FedRAMP Moderate authorized nor documented as meeting FedRAMP Moderate equivalency

Encryption that is strong but not FIPS-validated, which can’t be accepted for protecting the confidentiality of CUI

Multifactor authentication on remote access but not on privileged local access or on network access for every user

Audit logs collected but never reviewed, correlated or tied to an alerting process

An SPRS score that counted partially implemented requirements as met

MSPs with administrative access to the CUI environment and no documented split of responsibilities

Industries

Where CMMC reaches.

CMMC follows the information, not the industry label. If FCI or CUI reaches you through a defense contract or a prime, so does CMMC.

Aerospace & defense manufacturing

Airframe, propulsion, avionics and munitions programs share drawings and specifications marked as controlled technical information with every tier of the supply chain.

Machine shops & precision manufacturing

One part made to a DoD drawing can bring CUI onto your CAM workstations, CNC controllers and shop-floor file shares.

Engineering & R&D firms

Design work, test data and technical reports for defense programs are often CUI from the moment you create them.

Software & SaaS selling to the DoD

Source code, configuration data and support tickets tied to a defense customer can be CUI, and your platform can become a service provider inside someone else’s scope.

IT service providers & MSPs

When you administer a defense contractor’s systems, your tools and people sit inside their assessment as Security Protection Assets, and they will ask how you meet the requirements you take on.

Universities & research labs

Sponsored research and DoD funding can carry CUI and DFARS clauses into environments built for openness.

Logistics, shipbuilding & maintenance

Manifests, maintenance records and technical manuals for defense equipment carry FCI, and often CUI.

Professional services holding FCI

Staffing, consulting, training and facilities firms that hold only contract information still face Level 1 and its annual affirmation.

Where testing fits

The tests CMMC calls for, from the same team.

Vulnerability assessment

Requirement RA.L2-3.11.2 calls for periodic vulnerability scanning and scanning when new vulnerabilities are identified, and RA.L2-3.11.3 for remediating them according to risk; assessors ask for the scan results and the remediation trail.

What the test covers

Internal network pentest

An internal test shows whether a compromised workstation can reach CUI, which is direct evidence for access control and boundary requirements. Level 3 adds a penetration testing requirement from NIST SP 800-172 (CA.L3-3.12.1e).

What the test covers

Network segmentation test

If an enclave is what keeps the rest of your network out of scope, a segmentation test proves the boundary holds — support for SC.L2-3.13.1 and for the scoping argument itself.

What the test covers

Cloud configuration review

Government cloud tenants are where CUI often lives. A configuration review checks them against the requirements you claim and the responsibilities you inherit from the provider.

What the test covers

External network pentest

Internet-facing systems are the front door to the CUI environment; testing them gives you boundary protection evidence and real findings to fix before an assessor looks.

What the test covers

Social engineering

Security awareness training is a Level 2 requirement, and Level 3 adds training focused on social engineering and advanced threats; a phishing exercise shows whether that training changes behavior.

What the test covers

Wireless network pentest

Level 2 requires you to authorize wireless access and protect it with authentication and encryption (AC.L2-3.1.16 and 3.1.17); a wireless test shows whether those controls hold in practice.

What the test covers
Glossary

The CMMC vocabulary, in plain words.

FCI Federal Contract Information
Information provided by or generated for the government under a contract that is not intended for public release. Protecting it is the subject of Level 1.
CUI Controlled Unclassified Information
Information the government creates or possesses, or that you create for it, which a law, regulation or policy requires to be safeguarded. The NARA CUI Registry lists the categories. Protecting it is the subject of Levels 2 and 3.
CTI Controlled Technical Information
Technical information with military or space application, such as drawings, specifications and engineering data, that carries a distribution restriction. The CUI category manufacturers and engineering firms meet in drawings and specifications.
OSA Organization Seeking Assessment
Any company going through a CMMC assessment, whether a self-assessment or a third-party one.
OSC Organization Seeking Certification
A company going through a certification assessment by a C3PAO or DIBCAC.
C3PAO Certified Third-Party Assessment Organization
An organization authorized by the Cyber AB to perform Level 2 certification assessments. It may not consult for a company it assesses.
Cyber AB
The accreditation body for the CMMC ecosystem. It authorizes C3PAOs and oversees the people and organizations that train, consult and assess.
DIBCAC Defense Industrial Base Cybersecurity Assessment Center
The DoD’s own assessment team, part of DCMA. It performs Level 3 assessments and NIST SP 800-171 Medium and High Assessments.
SPRS Supplier Performance Risk System
The DoD system where assessment scores, CMMC statuses and affirmations are recorded, and where contracting officers check them.
CMMC UID CMMC Unique Identifier
The identifier SPRS assigns to each assessment, which you give contracting officers so they can confirm your status.
SSP System Security Plan
The document that describes your system boundary, environment and how each requirement is implemented. Without one, a Level 2 assessment cannot proceed.
POA&M Plan of Action and Milestones
The record of requirements not yet met, with owners and dates to close them. CMMC limits which requirements may sit on one.
CRMA Contractor Risk Managed Asset
An asset that can, but is not intended to, handle CUI because of the policies and controls you have in place.
SPA Security Protection Asset
An asset, person or provider that delivers security functions to the CUI environment, such as identity, logging or firewall services.
ESP External Service Provider
Any outside party that provides services touching your CUI environment or its security, including MSPs, MSSPs and cloud providers.
CSP Cloud Service Provider
An external service provider offering cloud services. If it handles CUI for you, it must be FedRAMP Moderate authorized or equivalent.
CRM Customer Responsibility Matrix
The document that splits each requirement between you and a provider: theirs, yours or shared.
FIPS-validated
Cryptography whose modules are validated under the NIST Cryptographic Module Validation Program. Required where encryption protects the confidentiality of CUI.
DFARS 252.204-7012
The contract clause requiring NIST SP 800-171 protection for covered defense information, rapid incident reporting to the DoD and flow-down to subcontractors.
DFARS 252.204-7019 and 7020
The clauses requiring a current NIST SP 800-171 assessment score in SPRS and access for the DoD to verify it.
DFARS 252.204-7021
The clause that puts a CMMC level into a contract, requires the status to stay current and requires flow-down to subcontractors.
Affirming official
The senior-level representative of your company who affirms in SPRS that you meet, and continue to meet, the requirements of your level.
Enclave
A deliberately narrow environment where CUI lives, so that the rest of the company falls outside the assessment.
Conditional status
A Level 2 or Level 3 status granted when the minimum score is met and every open item may sit on a POA&M. It expires unless a close-out assessment confirms the gaps are closed in the window the rule sets.
Final status
The status you hold when every requirement of your level is met, either at assessment or after a POA&M close-out.
NIST SP 800-171A
The companion publication that sets the assessment objectives behind each NIST SP 800-171 requirement. Assessors test at this level of detail.
Questions

What buyers ask about CMMC.

Which CMMC level do we need?

The information decides, and the solicitation confirms. If you only handle FCI, Level 1 applies. If you handle CUI, Level 2 applies, and the solicitation states whether a self-assessment or a C3PAO certification assessment is required. Level 3 is identified by the DoD for specific programs. Readiness reads your contracts, your CUI flows and the clauses your prime flows down, and gives you a written answer rather than a guess.

Can CyberlySecure certify us or perform the C3PAO assessment?

No. Level 2 certification assessments are performed only by C3PAOs authorized by the Cyber AB, and Level 3 assessments only by DIBCAC. CyberlySecure is not a C3PAO and holds no Cyber AB designation. That separation works in your favor: a C3PAO can’t consult for a company it assesses, so readiness and assessment have to come from different firms anyway, and we stay on your side throughout.

What’s the difference between a Level 2 self-assessment and a C3PAO assessment?

Both measure the same 110 requirements and the same NIST SP 800-171A objectives. In a self-assessment, you score yourself and your senior official affirms the result in SPRS. In a certification assessment, an independent C3PAO examines your documents, interviews your people and tests your systems before issuing a status. The contract decides which one you face, but the preparation is identical: a self-assessment that wouldn’t survive a C3PAO is a liability, not a shortcut.

Can we get certified while some requirements are still open?

Sometimes. At Level 2, you can reach Conditional status if your score meets the minimum the rule sets — 88 of a possible 110 points — and every open item is one the rule allows on a POA&M. Higher-weighted requirements generally can’t be deferred, and conditional status expires unless a POA&M close-out assessment confirms the gaps are closed in the window the rule sets. Level 1 allows no POA&M at all. Readiness tells you early which gaps you must close before the assessment, not after.

Do we have to move to a government cloud?

Not necessarily. Any cloud service that stores, processes or transmits CUI must be FedRAMP Moderate authorized or meet FedRAMP Moderate equivalency as the DoD defines it, and export-controlled data adds its own restrictions on who can access it. Many companies move CUI to a government cloud tenant; others keep it in a tightly scoped enclave or a different authorized service. Readiness weighs those options against your contracts, your data and your people.

How does NIST SP 800-171 Rev 3 affect CMMC?

CMMC Level 2 assesses against Rev 2, as the program rule specifies, and the DoD has kept DFARS contracts on Rev 2 for now through a class deviation. For now, build and assess to Rev 2, and note where Rev 3 changes the picture so the work carries forward when the requirement eventually moves.

What is our senior official actually affirming?

That the company meets, and continues to meet, the requirements of the level it claims. Affirmations are entered in SPRS at the assessment, at least annually afterward and after a POA&M close-out. Because an inaccurate affirmation can create False Claims Act exposure, the official needs evidence, not reassurance — readiness gives them the record behind the signature.

When does CMMC reach our contracts?

It already can. The DFARS rule took effect on November 10, 2025, and the DoD is bringing requirements in over four rollout periods that begin on November 10 of 2025, 2026, 2027 and 2028. From November 10, 2026, applicable solicitations can require Level 2 (C3PAO) certification as a condition of award. Your solicitations and your prime’s flow-downs say exactly which level and assessment type apply; readiness reads them with you and tells you what that means for your next bid.

Does CMMC apply to option periods on contracts we already hold?

It can. From the start of the rollout, the DoD may require a CMMC status before it exercises an option, and from full implementation on November 10, 2028, CMMC requirements apply to option periods on applicable contracts generally. A contract you already hold can bring CMMC with it at its next option, so the status you need is the one your next option calls for, not only your next new award.

Our prime flowed CMMC down to us. What does that mean for subcontractors?

DFARS 252.204-7021 requires a prime to flow the CMMC requirement down to every subcontractor that will process, store or transmit FCI or CUI, at the level that matches the information that subcontractor receives. The prime also has to confirm you hold that status before awarding the work. If you will receive only FCI, Level 1 is your requirement even when your prime needs Level 2. Readiness pins down what you actually receive, so you build to the right level rather than the highest one mentioned.

Is our MSP in scope?

If your MSP or MSSP provides security functions to the CUI environment, yes: its tools, people and access are Security Protection Assets inside your assessment. A provider that is not a cloud service provider does not need its own CMMC status to support you, but your assessor will examine what it does on your behalf. A customer responsibility matrix that matches the provider’s own documentation is the evidence that holds this together, and readiness builds it with you and your provider.

We handle export-controlled data. What changes?

ITAR and EAR govern who may access the data, generally limiting it to US persons unless a license allows otherwise, and constrain where it is stored and who supports the systems that hold it. CMMC does not replace those rules; it sits beside them. That shapes your cloud tier, your support providers and your access controls. Readiness maps where export-controlled data goes and checks your boundary and providers against both sets of obligations; your export-compliance counsel remains the authority on licensing.

Microsoft 365 commercial, GCC or GCC High: which one?

They are different service tiers, and they differ in the authorizations they carry, where data is stored, who can support it and whether they are built for export-controlled data. Which fits depends on the CUI you hold, whether ITAR or EAR data is involved and what your contracts and primes require. Readiness compares your data with each tier’s published documentation and the DoD’s FedRAMP Moderate equivalency requirements. CyberlySecure sells no licenses, so the answer follows your data, not a reseller margin.

What if our earlier self-score was wrong?

Correct it. Update your SPRS entry to a score you can support, put a plan behind the open requirements and make sure your next affirmation rests on evidence. An inflated score left in place is the exposure; a corrected score with a credible plan is a position you can defend. Talk to counsel about any past affirmation. Readiness rebuilds the score requirement by requirement so the new number holds when someone checks it.

What does Level 3 require before we start?

Final Level 2 (C3PAO) status for the same assessment scope. Level 3 then adds 24 requirements selected from NIST SP 800-172, aimed at advanced persistent threats, and DIBCAC performs the assessment. Level 3 applies only to programs the DoD identifies in the solicitation, and a company that faces it goes through both assessments in sequence. Readiness prepares both, on one consistent scope.

Is a readiness assessment required?

No. The rule does not require readiness work or any particular provider for it. But a C3PAO assessment is a single examination with consequences for award, and a self-assessment carries a senior official’s affirmation to the government. Finding your gaps beforehand, with people on your side of the table, is how you avoid learning about them from the assessor or from a contracting officer.

Should we build to NIST SP 800-171 Rev 3 instead of Rev 2?

Build to Rev 2. It is the version 32 CFR Part 170 names for CMMC Level 2, and the one your assessor will test against; moving CMMC to Rev 3 would take a change to the rule. Rev 3 reorganizes the requirements and adds organization-defined parameters, so readiness notes where your controls already meet its wording, and the move costs less when it comes.

Why can’t the firm that prepares us also assess us?

Because an assessor has to be independent of the work it judges. A C3PAO may not assess a company it has provided CMMC consulting to, and DIBCAC is part of the DoD itself. The separation protects you as well: the people helping you find and fix gaps sit on your side of the table, and the people deciding your status come to it fresh.

Do we need a Registered Practitioner Organization to prepare?

No. Nothing in the rule requires your preparation to come from a Cyber AB-registered provider; what an assessor weighs is your evidence, not who helped you build it. To be clear about where CyberlySecure stands: it holds no Cyber AB designation. It is not a C3PAO and not a Registered Practitioner Organization. That keeps the line clean: the firm preparing you is never the firm deciding your status.

How long does a CMMC status last?

Level 1 (Self) is renewed every year with a fresh self-assessment and affirmation. Level 2 and Level 3 statuses run on a triennial cycle, with an affirmation every year in between. Conditional status lasts only for the close-out window the rule sets. A significant change to the environment you were assessed on can also call for a new assessment, which is why affirmation upkeep tracks change, not just the calendar.

What will an assessor actually look at?

Three kinds of evidence for every assessment objective: documents they examine, such as policies, the SSP and records; people they interview; and systems they test. The CMMC Assessment Guide for each level sets out the objectives and the methods. A requirement is met only when every objective behind it is met, which is why readiness works at the objective level rather than the headline of each requirement.

Can we reuse our SOC 2 or ISO 27001 work?

Partly. Policies, risk assessments, access reviews and logging built for SOC 2 or ISO 27001 often answer many CMMC requirements. But CMMC adds a CUI-specific boundary, FIPS-validated cryptography, DFARS incident reporting and evidence at the level of each assessment objective, and a SOC 2 report or ISO certificate is not accepted in place of a CMMC assessment. Readiness maps what you have so you build only what is missing.

Is CMMC on your desk?

One conversation with someone who does this work. You leave knowing where you likely stand and what readiness would involve for you.

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