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What Is CMMC? Simple Answers for DoD Subcontractors

 

What is CMMC?

CMMC (Cybersecurity Maturity Model Certification) is a U.S. Department of Defense program that requires contractors and subcontractors to meet specific cybersecurity standards in order to work on DoD contracts.

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If your company handles Controlled Unclassified Information (CUI) or supports a prime contractor that does, CMMC determines whether you are eligible to bid on or perform certain defense-related work.

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CMMC is not optional once it is contractually required.

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Who does CMMC apply to?

CMMC applies to:

  • Prime contractors working directly with the DoD

  • Subcontractors that support prime contractors

  • Small businesses and niche suppliers, not just large defense firms

 

If you receive CUI from a customer or touch systems that store, process, or transmit CUI, CMMC likely applies to you.

 

Many subcontractors are impacted even if they never contract directly with the DoD.

 

What problem is CMMC trying to solve?

CMMC was created to reduce:

  • Data breaches involving defense information

  • Weak cybersecurity practices in the defense supply chain

  • Inconsistent application of security requirements

 

Before CMMC, many contractors self-attested to compliance with limited verification. CMMC introduces standardization and validation.

 

What are the CMMC levels?

CMMC currently has three levels, each aligned to different risk profiles.

 

CMMC Level 1

  • Focuses on basic safeguarding requirements

  • Applies to organizations that handle Federal Contract Information (FCI) only

  • Typically assessed via self-assessment

 

CMMC Level 2

  • Aligns with NIST SP 800-171

  • Applies to organizations handling Controlled Unclassified Information (CUI)

  • Requires documented policies, procedures, and implemented controls

  • Assessment may be self-assessment or third-party, depending on contract

 

CMMC Level 3

  • Intended for the highest-risk programs

  • Builds on Level 2 with additional controls

  • Involves government-led assessments

 

Most subcontractors impacted by CMMC fall under Level 2.

 

What is CUI and why does it matter?

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CUI (Controlled Unclassified Information) is sensitive government data that is not classified but still requires protection.

 

Examples include:

  • Technical drawings

  • Engineering data

  • Export-controlled information

  • Certain contract documents

 

If your systems store or access CUI, CMMC Level 2 requirements apply.

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Is CMMC required right now?

CMMC is being rolled out gradually through DoD contracts.

 

You are required to meet CMMC requirements when:

  • Your contract includes CMMC requirements, or

  • A prime contractor flows CMMC requirements down to you

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ou may not see “CMMC” explicitly mentioned yet, but related requirements often appear via:

  • DFARS clauses

  • Security questionnaires

  • Contract language from primes

 

Waiting until a contract requires CMMC is often too late.

 

What does CMMC require a subcontractor to do?

At a high level, CMMC requires subcontractors to:

  • Implement defined cybersecurity controls

  • Document policies and procedures

  • Maintain system security documentation

  • Address gaps through remediation plans

  • Demonstrate compliance through assessment

 

For Level 2, this means aligning your environment with NIST SP 800-171.

 

CMMC includes processes, documentation, and governance.

 

Is CMMC just paperwork?

No. Documentation is required, but controls must be implemented and operating.

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Common areas where subcontractors struggle:

  • Asset inventories

  • Access control and MFA

  • Logging and monitoring

  • Incident response procedures

  • Vendor and subcontractor management

 

CMMC assessments evaluate both design and implementation.

 

How long does CMMC take for a small subcontractor?

Timelines vary, but a realistic range for CMMC Level 2 is:

  • 3–6 months for organizations with moderate maturity

  • 6–12 months for organizations starting from minimal controls

 

Delays are most often caused by:

  • undocumented systems

  • unclear CUI boundaries

  • underestimating policy and evidence requirements

 

Starting early is one of the biggest success factors.

 

What happens if we’re not CMMC compliant?

If CMMC is required and you are not compliant:

  • You may be disqualified from bidding

  • You may lose existing contract opportunities

  • Prime contractors may remove you from approved vendor lists

 

CMMC is becoming a business eligibility requirement, not just a security checkbox.

 

Do we need a third-party assessment?

It depends on the contract.

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Some Level 2 environments allow self-assessment, while others require assessment by a C3PAO (Certified Third-Party Assessment Organization).

 

Even when self-assessment is permitted, documentation and evidence standards remain high.

 

How subcontractors should approach CMMC.  A practical approach includes:

  • Defining CUI scope clearly

  • Performing a gap assessment against NIST 800-171

  • Remediating high-risk gaps first

  • Documenting systems, policies, and procedures

  • Preparing assessment-ready evidence

 

Treat CMMC as a risk and business readiness project, not just an IT task.

 

How Security Pursuit helps

Security Pursuit supports DoD subcontractors with:

  • CMMC gap assessments

  • Readiness planning and remediation guidance

  • Penetration testing aligned to CMMC environments

  • Documentation support and assessment preparation

 

Our approach focuses on practical compliance that stands up to real assessment scrutiny.

Last updated: February 2026

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