MAD Security Blog | Cybersecurity For Defense Contractors

What are the CMMC Requirements?

Written by MAD Security | June 17, 2025

What are the CMMC Requirements?

If your business supports the Department of Defense in any way — as a contractor, subcontractor, or vendor — then meeting CMMC requirements isn’t just a nice-to-have. It’s a must. The Cybersecurity Maturity Model Certification (CMMC) 2.0 sets the standards for how defense partners must protect sensitive government data.

Whether you handle Controlled Unclassified Information (CUI), Federal Contract Information (FCI), or both, knowing what CMMC expects of you is the first step toward protecting your business and securing future opportunities.

At MAD Security, we walk alongside you at every stage of that journey. Let’s break it all down.

Why the DoD Created CMMC

The Department of Defense launched CMMC to address a growing concern: sensitive data across the defense supply chain was increasingly at risk. While many contractors were expected to follow frameworks like NIST SP 800-171, enforcement was limited. CMMC changes that by requiring organizations to prove they’re following proper cybersecurity practices.

 

If you’re working on defense contracts, you’re expected to meet the level of CMMC that matches the sensitivity of the information you manage. Non-compliance can delay or disqualify you from opportunities. Being prepared means protecting national security, meeting contract terms, and staying competitive in the defense sector.

 

What Kind of Data Does CMMC Protect?

CMMC focuses on two critical types of information:

Federal Contract Information (FCI)

This includes any non-public information provided by or generated for the government as part of a contract. Think pricing, project schedules, and supplier lists.

Controlled Unclassified Information (CUI)

CUI is more sensitive. It includes technical drawings, design specifications, and other defense-related information that isn’t classified but still needs to be protected.

If you work with either of these, you’re in scope for CMMC.

 

The 3 CMMC Levels and What They Require

CMMC 2.0 introduced a simplified model with three cybersecurity maturity levels. Each one has its own set of requirements based on the data you handle.

Requirements:

  • 17 core cybersecurity controls based on FAR 52.204-21
  • Includes access controls, password protection, physical security, and basic training
  • No POA&Ms (Plan of Action and Milestones) allowed
  • Assessment: Self-assessment submitted annually to the SPRS system

 

Requirements:

  • 110 security controls aligned with NIST SP 800-171
  • Covers areas like encryption, system monitoring, incident response, and documentation
  • POA&Ms are allowed but must be resolved within 180 days
  • Assessment:
    • Self-assessment for some non-prioritized contracts
    • Third-party assessment (C3PAO) required for more critical projects
  • Annual affirmations are required to stay compliant

 

Requirements:

  • Builds on Level 2 with additional controls from NIST SP 800-172
  • Emphasizes real-time monitoring, threat detection, and incident response
  • POA&Ms must be resolved in 180 days
  • Assessment: Triennial, government-led reviews conducted by DIBCAC
  • Annual affirmations are also required

Most contractors will fall into Level 1 or Level 2. Knowing which level applies to your work is an important first step.

 

CMMC Requirements for Subcontractors

If you’re a subcontractor, CMMC still applies. The level you need to meet depends on what kind of data you handle:

  • FCI only: Level 1
  • CUI: Level 2
  • Highly sensitive CUI for national security projects: Level 3

Prime contractors are responsible for ensuring their subs meet the right level. That means flow-down requirements will show up in your contracts, and non-compliance could cost you your spot on the team.

What Happens During an Assessment?

CMMC assessments help determine whether your organization is doing what it says it's doing to protect data.

Self-Assessments

    • Required for Level 1 and some Level 2 contracts
    • You’ll assess your own compliance and submit results to SPRS
    • Annual updates are expected

Third-Party Assessments

    • Required for prioritized Level 2 contracts
    • Conducted by an accredited C3PAO
    • Every 3 years

Government Assessments

    • Required for Level 3
    • Led by DIBCAC
    • Involves deeper technical and documentation reviews

 

POA&Ms and What to Do After Your Assessment

If your assessment uncovers any issues, you’ll need to create a Plan of Action and Milestones (POA&M). This is a formal plan that shows how you’ll close the gaps.

Each plan should include:

  • The issue
  • Steps for remediation
  • Who is responsible
  • Deadlines and progress milestones

At Levels 2 and 3, all POA&Ms must be resolved within 180 days. After that, continuous monitoring is expected to maintain your compliance over time.

 

The CMMC Rollout Timeline

CMMC is being implemented in phases between 2024 and 2028. Here’s a snapshot of what to expect:

 

Since certification can take a year or more to prepare for, the best time to begin is now.

 

Why CMMC Compliance Pays Off

CMMC certification isn’t just about avoiding risk. It creates real advantages for your business:

  • Stay Eligible: Certification is quickly becoming a non-negotiable requirement
  • Build Trust: Both the DoD and prime contractors want to work with secure partners
  • Improve Security: Stronger systems mean fewer breaches and lower risk
  • Stand Out: Being ready early makes your business more attractive to partners

 

How MAD Security Helps You Get There

We’re not just consultants. MAD Security is CMMC Level 2 Certified, has a perfect SPRS score of 110, and serves as a Registered Provider Organization (RPO). We’ve helped both contractors and C3PAOs navigate the path to certification and stay ready long-term.

Our services include:

We don’t leave you guessing. We walk with you every step of the way.

 

Ready to Move Forward?

If CMMC applies to your business — and it likely does — now is the time to get ahead. Preparing early puts you in a strong position when contracts start requiring certification.

Ready to take the next step? Schedule a free CMMC consultation with MAD Security. We’ll help you assess your current posture, understand what level you need to meet, and create a clear path to certification.

 

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