CMMC LaunchPad

CMMC Information

The whole CMMC 2.0 process can feel overwhelming. It’s best to view your compliance journey as a step-by-step process. We’re here to provide everything you need to get compliant quickly. Some advice before you begin this process:

An Overview of CMMC 2.0 and DFARS

CMMC 2.0 and DFARS together form the Department of Defense’s framework for protecting sensitive defense information across the Defense Industrial Base. DFARS clauses—particularly DFARS 252.204-7012—contractually require contractors and subcontractors to implement NIST SP 800-171 controls, report cyber incidents, and safeguard Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). CMMC 2.0 reinforces these requirements by introducing a three-tiered model with assessment and accountability mechanisms to verify that cybersecurity controls are properly implemented, whether through self-assessments or third-party evaluations, thereby improving consistency, reducing risk, and strengthening national security.

What's required

To comply with CMMC 2.0 and DFARS, organizations in the Defense Industrial Base (DIB) must meet a combination of technical, procedural, and contractual requirements designed to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).

First, companies must implement the required cybersecurity controls based on the level of data they handle. Most contractors handling CUI must comply with NIST SP 800-171, which includes 110 security controls across areas such as access control, incident response, configuration management, and system integrity. Organizations handling only FCI must meet more basic safeguarding requirements aligned with FAR 52.204-21. These controls must be fully implemented, documented, and operational—not just planned.

Second, organizations must document and assess their compliance posture. This includes maintaining a System Security Plan (SSP) that describes how each required control is implemented, along with a Plan of Action & Milestones POA&M
A Plan of Action and Milestones, or POA&M, is a document that outlines the action items needed to achieve compliance and the timeline for achieving it.
for any gaps. Under DFARS, companies must perform a NIST 800-171 self-assessment and submit a score to the Supplier Performance Risk System (SPRS). Under CMMC 2.0, organizations may be required to either self-assess annually or undergo a third-party CMMC assessment, depending on the contract requirements.

Finally, companies must meet ongoing contractual and operational obligations. This includes flowing down DFARS and CMMC requirements to subcontractors, reporting cyber incidents to the DoD within required timeframes, preserving evidence, and maintaining compliance over time. CMMC 2.0 makes compliance a condition of contract award, meaning organizations must be able to demonstrate compliance before and throughout contract performance, not just attest to it.

CMMC 2.0 Levels

Level Description Practices Assessment Focus
Level 1 Foundational 15 practices based on FAR 52.204-21 Annual Self-assessment Safeguard FCI
Level 2 Advanced 110 practices aligned with NIST SP 800-171 Rev 2 Triennial third-party or Annual self-assessment Protection of CUI
Level 3 Expert 110+ practices (NIST 800-171 + subset of 800-172) Triennial government-led assessments Enhanced CUI Protection

What’s the future of CMMC 2.0?

The final 48 CFR rule was issued on September 10, 2025, giving Defense Industrial Base (DIB) contractors sixty days to prepare for the launch of Phase 1 of CMMC 2.0. That window has now closed, and we are officially in the first phase of implementation.

Phase 1 (the current phase)

All new DoD contracts require adherence to CMMC 2.0. For most organizations, self-attestation is sufficient at this stage—full C3PAO certification is not yet required for the majority of contractors.

Phase 2 — Begins November 10, 2026

Expanded requirements roll out, including mandatory third-party assessments for Level 2 where applicable. Organizations in these categories will need a full independent C3PAO certification.

Phase 3 — Early/Mid 2027

More DoD contracts will begin requiring full certification at higher levels (e.g., Level 2 or Level 3) as a condition of award.

Phase 4 — Q1/Q2 2028

CMMC 2.0 enters full implementation across applicable DoD contracts, making certification a standard contracting requirement.

Consequences of non-compliance

Non-compliance with CMMC 2.0 and DFARS can lead to loss of eligibility for DoD contracts, removal from subcontracting opportunities, and potential contract termination. Organizations may also face significant legal and financial consequences, including False Claims Act liability for inaccurate self-attestations, repayment of funds, and government enforcement actions. In addition, inadequate cybersecurity increases the likelihood of data breaches involving sensitive defense information, which can trigger mandatory reporting, audits, reputational damage, and long-term harm to a company’s standing within the Defense Industrial Base.

Getting Started

The first step in the process is getting a consultation. This service is free and requires no obligation.

Step 1: Determine Your CMMC Level

Identify which CMMC level (1, 2, or 3) applies based on the type of data (FCI/CUI) in your DoD contracts.

Step 2: Scope Your Environment & Assets

Pinpoint all systems, people, and processes handling Federal Contract Information (FCI) and CUI to define your compliance boundary.

Step 3: Conduct a Gap Analysis

Compare your current cybersecurity posture against NIST SP 800-171 (for Level 2) to find weaknesses.

Step 4: Implement Controls & Document

Build your System Security Plan (SSP) and Plan of Action & Milestones POA&M A Plan of Action and Milestones, or POA&M, is a document that outlines the action items needed to achieve compliance and the timeline for achieving it. to address gaps and formalize security.

Step 5: Engage Experts (MSP)

Find a Managed Service Provider (MSP) for ongoing support and implementation of technical controls.

Step 6: Select Compliant Technology

Leverage specialized tools, like Microsoft Government Cloud offerings, to help meet security requirements.

Step 7: Select an Auditor (C3PAO)

Schedule time for a C3PAO to conduct an audit.

Step 8: Complete the Assessment & Get Certified

Work with your C3PAO to undergo the official assessment and maintain continuous compliance.

Financial Assistance Resources

Federal & DoD Programs

Allowable Contract Costs

Federal & DoD Programs
The DoD allows folding CMMC compliance/assessment costs into contract bids as reimbursable expenses. 
Contact US

SBIR/STTR Grants

Federal & DoD Programs
Fund research for new cybersecurity tech, which can also aid compliance efforts.
Contact US

Project Spectrum

Federal & DoD Programs
Offers free CMMC training, tools, and advisor support for small businesses to navigate compliance.
Contact US

State & Local Initiatives

DCAP (Defense Cyber Crime Center)

Provides grants for gap analysis, technical assistance, and software/hardware for NIST 800-171 compliance.

Other State Programs

Many state/local agencies offer grants and educational resources for CMMC prep. Resources: A high level overview.

Additional Resources

Federal & DoD Programs