From Application to Approval: The Real Journey to CMMC Certification

Obtaining Cybersecurity Maturity Model Certification (CMMC) approval is a rigorous undertaking that calls for a cautious approach. 

Some defense contractors can achieve CMMC compliance in a few weeks. However, larger organizations may require several months of ongoing audits before they’re eligible for Department of Defense (DoD) contracts. 

To ace the CMMC certification process, in-depth preparation is critical. A significant part of the planning entails knowing what’s required of your organization at various stages of the compliance journey. 

Here’s a step-by-step guide to CMMC certification, from initial application to eventual approval. 

1. Understand the CMMC Levels

CMMC is a DoD program designed to enforce cybersecurity compliance across the Defense Industrial Base (DIB). 

Originally unveiled as CMMC 1.0 on January 31, 2020, the program has since undergone a raft of amendments. The latest iteration, CMMC 2.0, became operational on December 16, 2024. 

One of the standout reforms was the consolidation of maturity levels from five to three. Before applying for CMMC certification, it’s imperative to understand the CMMC maturity level applicable to your organization. 

The three levels include;

Level 1/Foundational

CMMC Level 1 focuses on implementing basic cybersecurity protocols like access controls. 

It applies to contractors that process Federal Contract Information (FCI), and requires compliance with 17 controls derived from the Federal Acquisition Regulation (FAR) clause 52.204-21).

Level 2/Advanced

If your business handles Controlled Unclassified Information (CUI), you automatically fall under CMMC’s Advanced Level. 

Level 2 contractors must fulfill 110 cybersecurity protocols outlined in the National Institute of Standards and Technology (NIST) 800-171.

Level 3/Expert

Level 3 is CMMC’s most sophisticated maturity level. It targets businesses that process highly sensitive CUI. 

To obtain certification here, you must comply with all Level 2 requirements plus the 24 controls in NIST SP 800-172.

2. Define the Assessment Parameters

The DoD allows Level 1 businesses to self-audit. 

However, most Level 2 and all Level 3 assessments must work with independent auditors. Those include a CMMC third-party assessor organization (C3PAO) for Level 2 and a Department of Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) auditor for Level 3. 

It’s also important to understand the assessment frequency. 

Level 1 contractors must self-assess annually, while the subsequent Levels require triennial audits.

3. Get Your SSP Ready

A System Security Plan (SSP) is a cybersecurity policy document highlighting the controls and procedures you’ve put in place to prevent breaches to your information systems. 

An SSP can offer useful glimpses into your cybersecurity posture. 

Therefore, it’s important to develop and update it ahead of the mandatory cyber audits. 

As CMMC is the focus, your SSP must align with the security controls for protecting FCI and CUI (depending on your CMMC maturity level).

4. Conduct a Gap Analysis

A gap analysis is precisely what it says – an assessment of security weaknesses in your company’s information system. 

The audit helps to uncover any vulnerabilities that could expose your organization to cyber-attacks, leading to an unprecedented data breach. It’s typically undertaken ahead of a mandatory independent assessment. 

You can conduct a gap analysis using your in-house cybersecurity team. But for unbiased audits, consider engaging an independent assessor. 

Some of the commonly audited assets include;

• Physical defense contract forms

• Hardware devices, such as SD cards and hard drives

• Software storage platforms, such as cloud storage

• Physical facilities where your organization’s information systems reside, such as data centers
• Any support infrastructures or auxiliary service providers

5. Self Audit

Self-auditing is a provision for CMMC Level 1 businesses. 

As with a gap analysis, you can undertake these assessments internally or by enlisting a reputable cybersecurity compliance agency. 

Either way, it’s considered a self-audit since it doesn’t necessarily require a C3PAO or DIBCAC official. 

Thoroughly scope your information systems, updating your cybersecurity policies accordingly. Then, forward the findings to the DoD’s Supplier Performance Risk System (SPRS). 

6. Apply For A C3PAO

Most DIB companies fall under Level 2. So, this is perhaps the most critical stage in your CMMC compliance journey. 

After undertaking a gap analysis and addressing any security gaps, proceed to contact a C3PAO. 

The Cyber Accreditation Body (AB) website maintains a list of fully authorized C3PAOs. Ensure the agency is duly accredited and not awaiting certification. 

To apply for a C3PAO;

• Head to the Cyber AB website and sample the updated registry of authorized C3PAOs

• Narrow down on the right assessor by researching their experience through client reviews, etc.

• Contact the C3PAO

• Wait for the C3PAO to confirm your identity, which may involve them soliciting your Commercial and Government Entity (CAGE) code

• They may also request your unique identifier (UID), especially if previous audits generated such

• Go over other deliverables, including project delivery timelines and assessment costs
• Sign a contract (if necessary)

7. Let the C3PAO Handle the Rest

A C3PAO-led assessment would typically unfold as follows;

Pre-Assessments

During pre-assessments, a C3PAO will collect initial scope information. This enables the agency to develop a basic assessment plan. 

The C3PAO will then identify responsible assessment personnel, complete critical artifact intake forms, and conduct a readiness review. 

Actual Assessments

The actual assessment is a structured process that can last a couple of weeks to several months. 

While the focus is on your information storage systems, a C3PAO will also conduct extensive staff interviews and review your cybersecurity policy documents. 

Assessment Review and Certification

C3PAOs typically maintain a workforce that includes actual CMMC assessors and quality assurance (QA) personnel. 

After undertaking each assessment, the auditors submit the findings for review by their QA staff. The QA personnel determines if the assessment was conducted following the industry’s procedures. 

If satisfied with the findings, a C3PAO will proceed to score the audits. You can obtain one of the following scores;

• Met – Fulfilled all Level 2 cybersecurity controls
• Not Met – The audit uncovered security gaps
• Not Applicable – Certain security controls were inapplicable to your organization

If weaknesses emerged during the audits, a C3PAO will forward a remediation request to the Cyber AB. The Cyber AB reserves the right to grant such requests. 

If everything looks great, the Cyber AB and the DoD will issue you a formal certification.

Expediting CMMC Compliance With Professional Help 

Navigating the CMMC landscape can be exasperating for many defense contractors. Fortunately, you don’t have to do all the legwork when you can tap into professional help. 

A reputable cybersecurity auditor can help you uncover and remediate security vulnerabilities in your information storage assets. The agency will especially scope for risks that could compromise the integrity of the CUI in your systems, potentially causing you to lose your CMMC certification. 

It doesn’t matter whether your maturity level allows for self-affirmations or not. Working with a professional auditor can accelerate the CMMC certification process, providing a defining edge in the competitive DIB landscape.