
Why Subcontractors Must Take CMMC 2.0 Seriously to Stay Eligible for Prime Contracts
Winning contracts as a subcontractor in the defense industry has always been about delivering quality work and building trusted relationships. Today, another critical factor has entered the equation: cybersecurity compliance.
With the rollout of CMMC 2.0, prime contractors are under strict pressure to ensure that every subcontractor in their supply chain meets minimum cybersecurity standards. If you cannot demonstrate your compliance, you risk losing eligibility for future contracts, no matter how good your work has been in the past.
Many subcontractors are feeling the pressure. Some are unsure what CMMC requires. Others are worried about the cost or complexity of becoming compliant. The good news is that with the right plan, you can survive this shift, protect your current opportunities, and even stand out in a tightening defense marketplace.
In this guide, we will walk you through why CMMC 2.0 matters, what prime contractors expect, common mistakes to avoid, and how you can build a compliance strategy that keeps you competitive and contract-ready.
Why CMMC 2.0 Matters for Subcontractors
For many subcontractors, cybersecurity has traditionally been seen as something the primes or government agencies handle. Today, that has changed. Under CMMC 2.0, every organization in the defense supply chain from the largest primes to the smallest subcontractors is expected to meet defined cybersecurity standards.
The reason is simple. Cyber attackers often look for the weakest link in the chain. Subcontractors, especially smaller businesses, have become prime targets because they often have access to sensitive information but fewer security resources. The Department of Defense (DoD) and prime contractors are now actively working to close this gap.
CMMC 2.0 formalizes that effort. Prime contractors must ensure that subcontractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) meet minimum cybersecurity requirements. If a subcontractor cannot show compliance, the prime risks penalties and they may have no choice but to find a more compliant partner.
For subcontractors, this means survival in the defense market now depends on cybersecurity readiness. It is no longer just about technical capabilities, pricing, or past performance. If you cannot demonstrate CMMC compliance, you may be passed over for new opportunities or even cut from existing contract work.
The good news is that becoming CMMC-ready is achievable. By understanding what is required and starting the journey now, subcontractors can protect their relationships with primes and secure their place in the future defense industrial base.
What Prime Contractors Expect from Subcontractors Under CMMC 2.0
Prime contractors are under serious pressure to ensure that every subcontractor in their supply chain meets CMMC 2.0 requirements. They can no longer afford to make verbal promises or informal assurances at face value. When a prime minister wins a Department of Defense (DoD) contract, they are expected to guarantee that their entire team, including subcontractors, can protect sensitive information properly.
Here is what prime contractors now expect from their subcontractors under CMMC 2.0:
Meet the Correct CMMC Level
Subcontractors must understand which CMMC level applies based on the type of data they handle.
- If you access Federal Contract Information (FCI), you will need to meet CMMC Level 1.
- If you access Controlled Unclassified Information (CUI), you will need to meet CMMC Level 2.
Provide Real Evidence of Compliance
Prime contractors are asking for more than promises. They need subcontractors to submit:
- A completed System Security Plan (SSP)
- A Plan of Action and Milestones (POA&M), if there are gaps
- A recorded SPRS score with the DoD
Accept Flow-Down Compliance Clauses
Subcontractors must be prepared to sign contract language that formally commits them to meeting CMMC requirements. These clauses protect the prime by making compliance a legal obligation for every partner. Meeting these expectations is not about perfect cybersecurity. It is about proving that you are taking the right steps, documenting your security posture, and showing that you are serious about protecting the mission.
Subcontractors who proactively prepare and communicate their compliance status will stand out as reliable, trusted partners, exactly the kind of partners primes are looking for today.
Common Mistakes Subcontractors Make (and How to Avoid Them)
Subcontractors are under a lot of pressure to get CMMC compliance right. It is easy to feel overwhelmed or unsure about what steps to take first. At MAD Security, we have seen firsthand the most common mistakes subcontractors make when navigating CMMC 2.0 and more importantly, we know how to help you avoid them.
Here are a few pitfalls to watch out for:
Waiting Until a Prime Asks for Evidence
Many subcontractors delay action until their prime contractor demands an SSP, POA&M, or SPRS score. By that point, it may already be too late. Preparing your documentation early protects your eligibility and shows primes you are serious about security.
Assuming CMMC Compliance Will Not Affect Your Business
Some subcontractors believe that cybersecurity is only a concern for large companies. Primes are required to flow compliance down to every partner. No subcontractor is too small to be held accountable.
Trusting Verbal Assurances Instead of Documenting Compliance
Telling a prime you are "good on cybersecurity" is no longer enough. Without written plans, policies, and formal assessments, you may not meet minimum requirements when an audit or contract review comes.
Ignoring the Importance of SPRS Scores
Many subcontractors are unfamiliar with the Supplier Performance Risk System (SPRS). Submitting a self-assessment and recording an SPRS score is now expected for contractors handling CUI, and primes are starting to request proof during partner evaluations.
The good news is that every one of these mistakes is fixable. By taking action now, subcontractors can stay competitive, protect their business relationships, and turn compliance into a strength instead of a stress point.
How Subcontractors Can Build a Practical CMMC Compliance Plan
Achieving CMMC compliance may seem daunting at first, especially for subcontractors balancing tight budgets and limited resources. The good news is that you do not have to overhaul everything at once. By following a structured, step-by-step approach, you can build a compliance plan that protects your business and keeps you eligible for prime contracts.
Here is a practical five-step path to getting started:
Identify Your CUI and FCI Exposure
The first step is knowing what you need to protect.
- Federal Contract Information (FCI): Information provided by or generated for the government under a contract.
- Controlled Unclassified Information (CUI): More sensitive data that requires specific safeguarding.
Understanding the type of data you handle determines which CMMC level applies to your organization.
Create a System Security Plan (SSP)
An SSP is a living document that outlines your current cybersecurity practices, controls, and policies.
Even a basic draft is better than waiting. Many primes will ask for this document early in the partner review process.
Complete a Self-Assessment and Generate Your SPRS Score
Subcontractors who handle CUI are expected to perform a self-assessment against NIST 800-171 and submit their SPRS score.
Recording your score, even if it is not perfect, shows your commitment to compliance and continuous improvement.
Prioritize and Tackle Remediation Actions
No one expects subcontractors to be perfect. However, focusing on key remediation areas like access control, incident response, and vulnerability management can quickly boost your readiness and strengthen your score.
Engage a Trusted Compliance Partner
Working with a knowledgeable advisor like MAD Security helps you avoid common pitfalls, build credible evidence, and meet your primes' expectations faster and more affordably.
Building a compliance plan is about making steady progress. Subcontractors who start early, document their efforts and communicate openly with their prime partners will not only survive under CMMC 2.0 they will thrive.
How MAD Security Helps Subcontractors Stay Competitive
Navigating CMMC 2.0 can feel overwhelming, especially when you are focused on delivering high-quality work and meeting tight contract deadlines. The last thing any subcontractor wants is to lose valuable prime relationships because of a missed compliance requirement. That is where MAD Security comes in.
At MAD Security, we specialize in helping small and mid-sized subcontractors build practical, affordable paths to CMMC compliance without disrupting day-to-day operations. We know what primes are looking for, and we know how to help you meet their expectations confidently.
Here is how we support subcontractors like you:
CMMC Gap Assessments
We review your current cybersecurity posture and identify where you meet CMMC requirements and where gaps exist. Our assessments are straightforward, practical, and designed to prioritize the most critical areas first.
System Security Plan (SSP) and POA&M Development
We help you create strong, credible documentation that primes expect, including a complete System Security Plan (SSP) and a realistic Plan of Action and Milestones (POA&M) to address any shortfalls.
SPRS Score Guidance
Our team guides you through the self-assessment and SPRS score submission process, ensuring that you meet reporting expectations and can present your readiness to prime contractors with confidence.
Ongoing Compliance and Cybersecurity Support
CMMC compliance is not a one-time event. We offer ongoing advisory and technical support to keep your security practices strong and your business contract ready year after year.
With MAD Security as your partner, you are not just checking compliance boxes. You are building a stronger, more competitive business that primes will want on their teams for years to come.
Protect Your Future: Stay CMMC 2.0 Compliant and Win More Prime Contracts
CMMC 2.0 is changing the defense contracting world, and subcontractors who act now will be the ones who thrive. Staying compliant is no longer optional. It is essential to protect your prime contracts, strengthen your business relationships, and secure your future in the defense industrial base.
The good news is you do not have to navigate this journey alone. With the right plan and the right partner, CMMC 2.0 compliance becomes a manageable, even empowering, part of your business growth strategy.
At MAD Security, we are here to guide you every step of the way from building your first System Security Plan to helping you stay ready for the contracts that will drive your success.
Frequently Asked Questions (FAQ) About CMMC 2.0 for Subcontractors
Do subcontractors have to comply with CMMC 2.0?
Yes. Subcontractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) must meet the appropriate CMMC 2.0 level based on the type of data they access.
What happens if a subcontractor is not CMMC compliant?
Subcontractors who cannot demonstrate compliance risk losing current contract opportunities, being removed from prime contractor supply chains, and missing out on future bids.
What level of CMMC compliance do subcontractors need?
Most subcontractors working with FCI will need CMMC Level 1 compliance. Those handling CUI will need to meet CMMC Level 2 standards.
How can subcontractors prove CMMC compliance to prime contractors?
Subcontractors can demonstrate readiness by providing a System Security Plan (SSP), a Plan of Action and Milestones (POA&M), and an SPRS score submission.