Contractors and subcontractors within the defense industrial base (DIB) are already grappling with conflicting market challenges and business priorities, but now find themselves also dealing with the need to become CMMC certified.
With CMMC certification requirements now in contracts many organizations we speak with are unsure about what CMMC 2.0 actually requires, which level applies to them, how much it will cost, and how quickly they need to act.
To make matters more challenging, CMMC 2.0 applies differently depending on the type of federal information you handle, whether you are a prime contractor or subcontractor, and how Controlled Unclassified Information (CUI) flows through your environment.
In this article, we’ll answer the eight most common CMMC compliance questions we hear from contractors and subcontractors. Our goal is to give you clear, practical information so you understand what CMMC 2.0 means for your business, what actions you should be taking now, and what risks come with delaying preparation.
By the end, you’ll have a better sense of where your organization stands today and what gaps you may need to address before your assessment, so you can protect your contracts, and keep bidding on and winning new ones to grow your business.
Phase 1 of the CMMC 2.0 requirements officially went into effect November 10, 2025, 60 days after the 48 CFR final rule was published in the Federal Register.
In a nutshell, the rule means that most DIB organizations will need to get CMMC certified.
Without the required CMMC assessment and certification, companies doing business with the federal government that handle certain federal information could end up putting the future of their companies at risk.
Unsure if your business is CMMC ready? Get a quick accurate snapshot in less than 5 minutes using our free CMMC Readiness Score Tool to see where you stand before your audit.
While much of CMMC 2.0 is not new, and in fact, has long been mandated as part of existing cybersecurity regulations, such as NIST SP 800-171, DFARS, and FAR—CMMC 2.0 attempts to streamline all of those regulations under a single umbrella or framework.
It also establishes an enforcement protocol, based on compliance and assessment standards set for businesses at three different levels.
Whether it’s questions about where to find controlled unclassified information (CUI) within your environment, the required protections to safeguard it, or the deadline to meet compliance, businesses have many questions related to CMMC 2.0.
Below, we’ve answered the eight most common CMMC compliance questions we hear from contractors and subcontractors working within the Defense Industrial Base.
With CFR 48 Final Rule now in effect, it means that CMMC 2.0 isn’t just an empty mandate. The government can now not only put the requirements in contracts and solicitations, but also enforce the requirements. This means that businesses found to not be in compliance could face stiff consequences.
Besides fines and penalties, DIB organizations that fail to implement the necessary security measures could also risk losing their federal contracts and being banned from bidding on future contracts.
For many small contractors and subcontractors, the loss of critical federal funding could result in an existential crisis, leaving them struggling to keep the doors open.
An organization’s CMMC level is determined by the type of federal data it handles. Businesses that only handle federal contract information (FCI) will be required to implement foundational cybersecurity controls (Level 1).
Level 2 and Level 3 organizations, on the other hand, handle both FCI and CUI, so they’re required to meet tougher assessment and compliance requirements. For businesses requiring Level 2 certification, this means they’ll need to fully implement all 110 security controls found in NIST SP 800-171.
To be clear, most Level 2 businesses will need to get assessed by an independent third-party assessor organization (C3PAO). That means they will also need to have a seperate readiness partner to help them get ready as they cannot use the same use the C3PAO they hired to conduct their CMMC audit to also prepare them.
Such assessments must take place every three years, with results submitted into the Supplier Performance Risk System (SPRS) online portal. On off years when a C3PAO audit is not being conducted, businesses must conduct a self-assessment, self-attest to the veracity of the results and continued compliance, and enter the data into the SPRS portal.
The answer to this question is—it depends. The length of time it will take for you to become compliant will depend on many factors, such as your existing cybersecurity measures, the size of your business, and the complexity of your IT environment.
That said, it can take companies an average of six to 18 months to become fully compliant.
Keep in mind that businesses requiring a C3PAO audit will also need to factor in additional time to schedule the audit, since there are a limited number of approved C3PAO assessors nationwide and slots have already started filling up.
While there is no specific deadline for DIB contractors to become CMMC compliant, the deadline will depend on a company’s existing contract renewal date, or in the case of new solicitations, the deadline for bid submissions.
It’s also important to note that for certain high priority contracts, the government has already made CMMC compliance mandatory.
Action steps contractors and their subs can take right now to start their CMMC 2.0 compliance process include scoping their CUI boundary, performing a gap analysis of the scoped area, and making sure that their system security plan (SSP) documentation to address any security deficiencies found is thorough and complete.
Business should also begin calling C3PAOs to get pricing and check availability to determine which company would be best for their organization/deadline.
As for postponing compliance, the best course of action is to take action now. Don’t wait!
There is no exact answer to this question: an organization’s size, the type of CUI they handle, the complexity of their IT environment, their current security posture, and their required CMMC level, are all factors that will determine how much compliance will cost.
With so many variables, it’s hard to pin down an exact number, but most small and mid-sized DIB organizations can expect to have to spend at least $35,000 for Level 1 compliance. Organizations at Level 2 can expect compliance preparation costs to jump to at least $50,000.
Businesses should understand going in that costs can add up quickly, with necessary readiness steps such as a preliminary readiness assessment, gap analysis, and (SSP) documentation pushing total costs to upwards of $100,000 or more for smaller organizations.
Large enterprise companies can expect CMMC compliance costs in the range of $500,000 to north of $1 million.
Also, it’s important to keep in mind that C3PAO audits and self-assessments are additional expenses on top of the compliance readiness costs.
For businesses at Levels 2 and 3, CMMC 2.0 certification is valid for three years, since that is the required interval for having an independent, third-party audit performed. Level 1 organizations must perform an annual self-assessment and re-attest to continued compliance each year.
There’s no getting around it. CMMC 2.0 is here, and delaying action is no longer a feasible option. The requirements are real, enforcement is underway, and eligibility for current and future Department of Defense contracts increasingly depends on your ability to demonstrate compliance at the required level.
As you’ve seen, many organizations struggle with the same challenges—uncertainty around their required CMMC level, where CUI exists in their environment, how prepared they truly are for an assessment, and what gaps could prevent them from passing. These questions are common, and they’re often not fully answered until late in the process, when time and options are limited.
Given this, if you’re a contractor or subcontractor within the DIB in Connecticut, it’s crucial that you have a plan in place to ensure that you can implement the right security measures to satisfy the CMMC requirements for your level.
If you don’t have an internal IT department with the time, know-how, and resources to properly assess your IT environment and put in place the right security tools and systems, then it may make sense for you to partner with a local managed IT services provider (MSP).
At Kelser, our CMMC 2.0 Compliance Forward readiness plan is a comprehensive roadmap designed to meet each client where they are and help guide them effectively and efficiently through their compliance journey, making sure that nothing gets overlooked so that you’re ready to go when it’s time for your official assessment.
Our strategic readiness plan, tailored to your business, includes:
If you’re looking for a quick, no-obligation way to understand your current position, our CMMC Readiness Score Tool is a practical first step. It’s a self-service assessment designed to help prime contractors and subcontractors identify what may be missing across key areas like CUI discovery and level determination, gap analysis and remediation, SSP documentation, and audit preparedness.
If you’d prefer to talk through your situation with an expert, you can also book a no-cost consultation with our CMMC-licensed professional, who has helped contractors and subcontractors successfully prepare for CMMC, NIST, and related cybersecurity requirements. This conversation is focused on understanding your environment, your contracts, and your next best steps—nothing more.
You don’t have to navigate this alone, and you don’t have to guess where you stand.