For many defense contractors, the road to CMMC Level 2 compliance can feel like navigating a maze with no clear map. With 110 security controls required at Level 2, organizations often find themselves asking the same question: Where do we even begin?
This sense of overwhelm is common and completely understandable. Between deciphering technical requirements, managing internal resources, and ensuring alignment with frameworks like NIST 800-171, it’s easy to feel paralyzed by the complexity of it all. But the key to progress isn't trying to tackle everything at once. It's starting with what's essential, achievable, and strategic.
That’s where CMMC Level 1 comes in.
With just 17 foundational practices, Level 1 focuses on protecting Federal Contract Information (FCI) and sets the groundwork for more advanced cybersecurity maturity. By starting with Level 1, contractors can build a strong compliance foundation, develop repeatable processes, and gain momentum without being overwhelmed by the full weight of Level 2 requirements.
If your organization is struggling to take the first step toward compliance, focusing on CMMC Level 1 controls is not just a good option: it’s the most strategic approach forward.
Level 1 includes 17 basic cybersecurity practices derived directly from FAR Clause 52.204-21, the Federal Acquisition Regulation that mandates baseline protections for FCI. These practices are straightforward but essential, covering fundamental controls such as access management, physical security, identification and authentication, and malware protection.
Any organization within the Defense Industrial Base (DIB) that handles FCI as part of its contractual obligations must meet these Level 1 requirements. This includes prime contractors and subcontractors, regardless of size or complexity, who support federal missions but do not handle Controlled Unclassified Information (CUI).
CMMC Level 1 is a mandatory requirement for all DoD contractors, serving as the baseline for cybersecurity compliance. Whether an organization aims to achieve Level 2 or Level 3, establishing a strong foundation with Level 1 is essential. The 17 practices outlined at this level are not mere formalities; they form the core framework for long-term compliance, operational resilience, and cybersecurity maturity.
By aligning with FAR 52.204-21 and implementing Level 1 effectively, your organization takes a critical first step toward CMMC readiness and long-term contracting success.
Jumping straight into CMMC Level 2 with its 110 complex controls can be like trying to scale a mountain without a base camp. That’s why beginning with CMMC Level 1 isn’t just a tactical move; it’s a strategic advantage. It allows your organization to take the first step on the cybersecurity maturity ladder with confidence, clarity, and control.
The 17 practices at Level 1 establish fundamental security hygiene. These are basic safeguards, including controlling system access, maintaining physical security, and enabling antivirus protection, measures that every organization, regardless of size or infrastructure, should have in place.
Starting at Level 1, contractors begin developing habits related to documentation, tracking, and evidence collection; key elements for success at Level 2. Establishing these workflows early makes them second nature when the stakes get higher.
Level 1 provides your team with the opportunity to understand the rationale behind cybersecurity policies, not just the technical details. It fosters a culture of compliance, where security is integrated into everyday operations. As you progress in the maturity model, your workforce is better prepared to adopt more advanced controls with minimal friction.
Contractors who attempt to tackle all 110 Level 2 controls simultaneously often face burnout, misallocation of resources, and scope creep. By focusing on Level 1 first, you prioritize the essentials, avoid wasting time, and gain early wins that boost momentum.
Beginning with Level 1 also helps organizations define the right security boundary or enclave, a critical step for accurate scoping. It allows you to identify inheritable controls those managed by a third party (e.g., MSSPs or cloud providers) which reduces the internal burden as you plan for Level 2.
In short, CMMC Level 1 serves as your launchpad, providing a scalable and strategic framework that enables future readiness. Just like climbing a ladder, every rung builds your strength and situational awareness for the next. Don’t skip the foundation; it’s what supports everything above.
Many of the core control families in Level 2, like Access Control (AC), Identification and Authentication (IA), and Physical Protection (PE), are introduced at Level 1. For example:
AC.L1-3.1.1, which limits system access to authorized users, maps directly to multiple Level 2 controls that expand access granularity, least privilege, and session controls.
PE.L1-3.10.1 on physical access sets the stage for broader physical and environmental protection required at Level 2.
By building these capabilities early, your team becomes familiar with both the concepts and implementation mechanics, creating a smoother transition to more advanced practices.
The tools, policies, and processes established for Level 1, such as antivirus solutions, access logs, and physical access reviews, can be scaled and adapted for Level 2. Implementing these in a thoughtful, modular way ensures you’re not redoing work later. For organizations using a Managed Security Services Provider (MSSP), many Level 1 practices can also be inherited or expanded as part of a managed CMMC roadmap.
Another key benefit of starting Level 1 is developing assessment-ready evidence practices early. Creating documentation and maintaining artifacts for the 17 controls prepares your organization for the more rigorous assessments of Level 2. Additionally, Level 1 practices impact your SPRS (Supplier Performance Risk System) score, which contracting officers increasingly use to evaluate cyber readiness.
Simply put, CMMC Level 1 serves as your strategic springboard, providing not only quick compliance wins but also a tactical advantage for meeting the full 110 controls of Level 2.
While the pressure to meet CMMC Level 2 compliance may tempt some contractors to jump straight into the full 110 controls, skipping Level 1 often leads to serious setbacks. Without a strong foundation, your cybersecurity efforts can quickly become disorganized, inefficient, and vulnerable, both technically and during assessments.
Lack of DocumentationWithout Level 1 as a starting point, organizations often fail to implement essential documentation practices. Policies, procedures, and evidence of artifacts get overlooked, leaving critical gaps that will be flagged during a CMMC assessment or SPRS score review. |
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Misapplied Technology Without Process
It’s easy to invest in expensive cybersecurity tools that promise compliance. Still, without the process discipline of Level 1 enforcement, these technologies are often misconfigured, underutilized, or not aligned with actual control requirements. |
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Overinvestment Without Governance
Jumping into advanced controls without governance leads to overcomplication and overspending. Level 1 helps establish the “why” and “how” behind security decisions, giving your organization strategic clarity before investing in Level 2 technical implementations. |
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Poor Scoping Decisions
Failing to properly define the scope of your information systems and FCI boundaries can lead to significant issues during assessments. Level 1 encourages thoughtful scoping and enclave design, critical steps for minimizing assessment complexity and cost. |
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Increased Audit Risk
When controls are deployed haphazardly or without clear documentation, your organization is exposed to higher assessment risk. Level 1 provides a structured, repeatable baseline that reduces this risk and demonstrates good faith compliance efforts. |
In short, skipping Level 1 is like building a house without a foundation. It may look impressive on the surface, but it won’t withstand the scrutiny of real-world compliance assessments.
Our Virtual Compliance Management (VCM) services are designed to simplify the process. We guide your team through the 17 Level 1 practices, aligning each control with your organization’s existing infrastructure, workflows, and risk profile. Whether you operate in the cloud, on-prem, or a hybrid environment, we tailor the controls to fit your operational reality, not the other way around.
We also offer fast-start gap assessments and hands-on coaching to help you identify compliance gaps, implement quick wins, and build repeatable processes. Our team supports the development of evidence-ready documentation from day one, making your journey toward Level 2 more efficient and assessment-ready.
Additionally, MAD Security helps you understand and improve your SPRS score, which is increasingly used to assess contractor cyber readiness. We ensure your score accurately reflects your actual security posture by guiding you through best practices for self-assessment and accurate reporting.
With MAD Security, you don’t just aim for compliance; you build a cybersecurity strategy that aligns with your business goals, contract obligations, and future CMMC roadmap.
When it comes to achieving CMMC Level 2 compliance, the smartest path forward begins with Level 1. These 17 essential practices are more than just a basic requirement; they form the foundation for long-term cybersecurity success. Level 1 is where organizations build structure, discipline, and confidence, making it easier to scale toward the full 110 controls required at Level 2.
Starting with Level 1, your organization gains more than just compliance; it gains clarity. This approach emphasizes simplicity, strategy, and sustainability, helping you avoid the confusion and burnout that often come from diving into advanced controls without a plan. With a solid Level 1 foundation, you’re better positioned to manage risk, satisfy federal contracting requirements, and demonstrate measurable cybersecurity maturity.
If your business handles Federal Contract Information (FCI) and wants to set the stage for seamless CMMC readiness, MAD Security is here to help. Our expert team will guide you through a customized, practical roadmap beginning with what matters most.
Are you ready to take the first step? Schedule your free CMMC Level 1 readiness consultation with MAD Security and start building the foundation your future contracts depend on.
Original Published Date: September 30, 2025
By: MAD Security