If you’re a defense contractor, achieving Cybersecurity Maturity Model Certification (CMMC) is no longer optional. It’s becoming a mandatory requirement to maintain your eligibility for working with the Department of Defense (DoD).
Under the Final CMMC Program Rule, initial CMMC requirements will take effect in early to
mid-2025, giving you limited time to prepare. Compliance is complex, requiring strict security controls to protect sensitive defense information.
Many contractors face the challenge of meeting certification requirements within a short timeframe while ensuring full compliance with DoD cybersecurity mandates.
This guide will help you understand when CMMC certification will be required, how to navigate the certification process, and how BEMO can help simplify compliance for your organization.
So, when will CMMC certification be required?
Key Takeaways
- CMMC certification becomes mandatory in early to mid-2025, with phased implementation continuing through 2026.
- The framework consists of three compliance levels, with increasing security requirements based on the sensitivity of the data you handle.
- Third-party assessments are required for CMMC Level 2 and Level 3, while self-certification is only allowed for Level 1.
- Failing to meet CMMC deadlines can result in contract loss, financial penalties, and reputational damage.
- The certification process typically takes 12 to 18 months and involves security assessments, control implementation, and extensive documentation.
- BEMO offers managed compliance services, automated monitoring, and expert guidance to help you achieve certification efficiently.
Table of Contents:
What is CMMC?
The Cybersecurity Maturity Model Certification is a Department of Defense (DoD) cybersecurity framework designed to enforce strict security standards for defense contractors and subcontractors like you.
CMMC protects sensitive unclassified information shared between the DoD and its contractors, reducing cybersecurity risks across the Defense Industrial Base (DIB).
Under the Final CMMC Program Rule, published in 2024, compliance will begin in early to mid-2025, as CMMC requirements start appearing in DoD contracts. This means that if you work with the DoD, you must meet specific cybersecurity standards to maintain your contract eligibility.
Achieving CMMC compliance can be challenging, requiring your business to implement stringent security measures, undergo formal assessments, and maintain ongoing certification.
However, compliance is no longer optional as contractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) must be CMMC-certified to continue working with the DoD.
As you’ll see below, there are several important components of CMMC.
Key Components of CMMC
The Cybersecurity Maturity Model Certification establishes structured cybersecurity requirements that you must implement to protect sensitive government data. The goal is to ensure that every organization in the Defense Industrial Base (DIB) meets strict security standards and maintains a strong cybersecurity posture.
The CMMC framework consists of structured cybersecurity requirements that defense contractors must implement to safeguard sensitive government data. The model is designed to ensure organizations across the supply chain meet minimum security standards and maintain a strong cybersecurity posture.
Here are the main components of CMMC:
Protection of Federal Contract Information (FCI)
If your business handles Federal Contract Information (FCI), (non-public information generated for or provided by the U.S. government under a contract), you need to implement basic cybersecurity safeguards to prevent unauthorized access.
While FCI is not classified, it still requires protection, and organizations working with FCI must comply with CMMC Level 1 requirements.
Safeguarding Controlled Unclassified Information (CUI)
Controlled Unclassified Information (CUI) includes sensitive government data that must be protected under federal regulations.
This may include technical specifications, research data, and defense-related communications. If your organization handles CUI, you must comply with CMMC Level 2 or Level 3, depending on the sensitivity of the data and the nature of the contract.
Tiered Compliance Levels
CMMC certification is divided into three levels, each with increasingly stringent security requirements:
- Level 1 (Basic Cyber Hygiene): You must implement 15 security practices from FAR 52.204-21 and conduct an annual self-assessment to remain compliant.
- Level 2 (Advanced Cybersecurity): This level requires compliance with 110 security controls from NIST SP 800-171. Depending on contract requirements, you may need either a self-assessment or a third-party certification every three years.
- Level 3 (Expert Cybersecurity): If your company handles highly sensitive CUI, you must comply with 110 controls from NIST SP 800-171 plus 24 additional controls from NIST SP 800-172. You will also need to undergo a DIBCAC (Defense Industrial Base Cybersecurity Assessment Center) assessment every three years.
Mandatory Third-Party Assessments
Unlike previous DoD cybersecurity requirements, self-certification is not enough for most organizations. If you are required to meet CMMC Level 2 or Level 3, your company must undergo an independent assessment conducted by a Certified Third-Party Assessment Organization (C3PAO) to verify compliance.
Ongoing Compliance and Recertification
Achieving CMMC certification means maintaining compliance through regular assessments and annual affirmations to ensure your security controls remain effective against evolving cyber threats.
Plan of Action and Milestones (POA&M) Limitations
If you fall short of meeting all security requirements for Level 2 or Level 3, you may submit a Plan of Action and Milestones (POA&M) to address specific security gaps. However, critical security requirements must be met upfront, and if you fail to close POA&M items within 180 days, your CMMC certification will expire.
Keeping these factors in mind, who will actually need CMMC certification?
Who Needs CMMC Certification?
If your business is part of the Defense Industrial Base (DIB) and handles Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), CMMC certification is mandatory. The specific level of certification required depends on the sensitivity of the data you process, store, or transmit.
Failing to comply with CMMC requirements can make your organization ineligible for DoD contracts, resulting in lost business opportunities. Below is a breakdown of which organizations must achieve certification.
Prime Contractors
As a prime contractor, you work directly with the Department of Defense (DoD) and are responsible for delivering defense-related products and services. You must achieve and maintain the required CMMC level for your contracts.
Beyond your own compliance, you must also ensure that all subcontractors, suppliers, and service providers in your supply chain meet CMMC requirements. Compliance extends beyond your organization and applies to every entity handling FCI or CUI.
Subcontractors
If your company operates as a subcontractor under a prime contractor, you must meet the same CMMC requirements. Even if you don’t work directly with the DoD, you still need to comply if you handle CUI or FCI on behalf of a prime contractor.
Most prime contractors are already enforcing CMMC compliance among their subcontractors, even ahead of the official contract requirement. If your company is part of a DoD contract supply chain, you should start preparing for certification as soon as possible.
IT Service Providers and Cloud Vendors
Managed service providers (MSPs), managed security service providers (MSSPs), and cloud service providers (CSPs) that store, process, or transmit DoD-related data must comply with CMMC standards. This includes businesses offering:
- Cloud storage and computing services
- Managed IT and cybersecurity services
- Network and infrastructure management
- Security monitoring and endpoint protection
If your cloud-based services support DoD contractors handling CUI, you must comply with CMMC Level 2 or higher. CSPs must use FedRAMP-authorized cloud environments that meet the DoD’s cybersecurity requirements.
Defense Manufacturers and Suppliers
If your business manufactures, assembles, or supplies parts and components for defense projects, CMMC compliance is required. This includes:
- Aerospace and defense manufacturers
- Electronics and sensor manufacturers
- Shipbuilding and military vehicle production
- Weapons system component suppliers
Because these companies often handle technical drawings, specifications, and defense-related intellectual property, they typically need CMMC Level 2 certification. You must also ensure that your internal IT infrastructure and supply chain partners remain compliant.
Software Developers
If your company develops software solutions for DoD contracts, you must comply with CMMC, especially if you process, store, or integrate CUI. This includes:
- Custom software developers creating tools for DoD projects
- Commercial off-the-shelf (COTS) software providers
- Open-source developers whose solutions are used by DoD contractors
If your business develops applications for secure communication, cybersecurity, logistics, or AI-driven defense tools, you must implement CMMC-aligned security controls at every stage, from development to deployment.
If you belong to one of these industries, you will need CMMC certification soon. The next step is understanding when CMMC certification will be required.
When Will CMMC Be Required?
The Department of Defense (DoD) officially published the Final CMMC Program Rule on October 15, 2024, with the rule going into effect on December 16, 2024. The first CMMC requirements will begin appearing in DoD contracts in early 2025.
This rule formally establishes the Cybersecurity Maturity Model Certification (CMMC) as a requirement under 32 CFR Part 170, meaning all contractors and subcontractors working with the DoD must comply with these cybersecurity standards.
CMMC Implementation Timeline
The rollout of CMMC requirements will occur in phases, with full enforcement expected by October 2026. Here’s a look at the timeline:
- Q1 2025: DoD will begin adding CMMC requirements to select Requests for Proposals (RFPs).
- Q3 2025: CMMC will start becoming a contractual requirement in certain defense contracts.
- October 2025: More contracts will require CMMC compliance, increasing enforcement across the Defense Industrial Base (DIB).
- October 1, 2026: Full CMMC implementation takes effect. Any organization handling Controlled Unclassified Information or Federal Contract Information, including Managed Service Providers (MSPs) and Managed Security Service Providers (MSSPs), must be certified.
Given this timeline, how long does it take to get CMMC certified?
How Long Does CMMC Certification Take?
Achieving CMMC certification is a multi-phase process that typically takes 12 to 18 months from start to finish. The exact timeline depends on organizational readiness, the scope of required security upgrades, and the level of certification needed.
CMMC Certification Timeline
Here’s a general breakdown of what to expect:
1. Preparation and Gap Analysis (3 to 6 months)
- Conduct an internal cybersecurity assessment to determine current compliance levels.
- Identify security gaps between existing controls and CMMC requirements.
- Develop a remediation plan to implement necessary security improvements.
2. Implementation of Security Controls (3 to 6 months)
- Deploy required security tools, policies, and procedures.
- Implement multi-factor authentication (MFA), endpoint security, and encryption protocols for handling CUI.
- Secure IT infrastructure, cloud environments, and access controls.
3. Operational Evidence Collection (3 to 6 months)
- Organizations must show ongoing compliance by documenting security controls in daily operations.
- Security practices must be consistently monitored and integrated into business workflows.
4. CMMC Assessment Process (1 to 3 months)
- Schedule a formal CMMC assessment with a Certified Third-Party Assessment Organization (C3PAO).
- Undergo a full review of cybersecurity documentation, policies, and technical controls.
- If any deficiencies are found, you may need to remediate and reapply for certification.
5. Certification and Maintenance (Ongoing)
- Once certified, your CMMC certification is valid for three years.
- Organizations must continuously monitor cybersecurity practices and conduct self-assessments to maintain compliance.
Why Start the CMMC Process Now?
With CMMC requirements rolling out in mid-2025, organizations that delay compliance efforts risk losing eligibility for defense contracts. Prime contractors are already requiring compliance from their subcontractors, so preparation should start now.
By beginning the CMMC certification process early, you can:
- Avoid last-minute security gaps that could delay contract eligibility.
- Spread out costs over time rather than facing sudden compliance expenses.
- Minimize operational disruptions by implementing security improvements gradually.
- Secure contracts ahead of competitors that wait too long to achieve compliance.
Many defense contractors and subcontractors are partnering with cybersecurity consultants or MSSPs to streamline compliance, reduce costs, and ensure a smooth certification process. If your organization hasn’t started yet, now is the time to take action.
Now that the timeline is clear, how much does CMMC certification cost?
CMMC Compliance Costs
The cost of CMMC compliance varies widely depending on factors such as organization size, cybersecurity maturity, and the required CMMC level.
Your total investment will depend on the volume of Controlled Unclassified Information you handle, your existing security infrastructure, and whether you choose to work with external consultants or managed security service providers.
Estimated Cost Range
Most organizations can expect to spend between $50,000 and $500,000 to achieve full CMMC compliance. This cost is broken down into several key areas:
- Gap Assessments and Consulting Fees: Engaging CMMC consultants, Registered Practitioners (RPs), or a Certified CMMC Assessor (CCA) to evaluate your cybersecurity posture and develop a remediation plan.
- Implementation Costs: Deploying security controls, upgrading infrastructure, and adopting secure cloud environments, such as FedRAMP-authorized cloud services for CUI protection.
- Third-Party Assessments: Hiring a Certified Third-Party Assessment Organization (C3PAO) to conduct a formal compliance evaluation. Costs vary depending on company size and complexity.
- Personnel Training and Documentation: Developing required CMMC policies, training staff on cybersecurity best practices, and ensuring all employees understand their security responsibilities.
- Ongoing Compliance Maintenance: Implementing continuous monitoring, conducting regular audits, and updating security documentation to maintain compliance after certification.
While these costs may seem high, failing to meet CMMC deadlines could have far more severe consequences.
What Are the Consequences of Missing the CMMC Deadline?
Failing to achieve CMMC certification on time could put your business at serious risk—not just in terms of contract eligibility, but also in financial, legal, and reputational aspects. Here’s what’s at stake:
Loss of DoD Contracts and Business Opportunities
CMMC compliance is a non-negotiable requirement for bidding on new DoD contracts. If your organization is not certified, you will be:
- Immediately disqualified from bidding on new federal contracts.
- Potentially removed from existing contracts requiring CMMC compliance.
- Excluded from the defense supply chain, as prime contractors require their subcontractors to meet the appropriate CMMC level.
Prime contractors are already enforcing CMMC readiness among their subcontractors, meaning non-compliant vendors risk being phased out long before full enforcement begins in 2026.
Financial and Reputational Consequences
The financial impact of missing the CMMC deadline goes beyond lost contracts. Your business may face:
- Revenue Loss: Losing DoD contracts and the inability to bid on future opportunities can result in significant financial setbacks.
- Operational Disruptions: Organizations that depend on DoD contracts may be forced to find alternative revenue streams, requiring shifts in business strategy.
- Reputational Damage: Non-compliance can signal weak cybersecurity practices, making it difficult to earn trust from both government agencies and private-sector partners.
Security and Legal Risks
Beyond financial concerns, failing to comply with CMMC standards exposes your organization and the DoD to increased cybersecurity threats.
- Increased Risk of Data Breaches: Without CMMC-required controls, your organization’s CUI and FCI remain vulnerable to cyberattacks, increasing the likelihood of data theft or unauthorized access.
- False Claims Act (FCA) Violations: Contractors that falsely claim compliance while working on DoD contracts may face serious penalties under the False Claims Act, including fines and potential legal action.
Given these risks, proactively preparing for CMMC certification is the best way to ensure compliance, security, and business continuity.
How to Prepare for CMMC Certification
Achieving CMMC certification requires a structured and methodical approach. Your first step is determining which CMMC level applies to your organization.
If you handle Controlled Unclassified Information, you’ll likely need Level 2 certification, while organizations dealing only with Federal Contract Information may qualify for Level 1.
Here’s how to prepare for certification efficiently and avoid compliance setbacks.
1. Conduct an Initial Assessment
Start by evaluating your current cybersecurity posture. This assessment will identify security gaps and determine where your organization falls short of CMMC requirements. Key actions include:
- Reviewing existing cybersecurity policies, procedures, and controls to measure compliance readiness.
- Comparing current practices against the 110 security requirements of NIST 800-171 (if pursuing Level 2 certification).
- Identifying weaknesses in access controls, encryption protocols, logging mechanisms, and incident response procedures.
- Documenting all findings, as this report will guide your compliance roadmap.
A thorough assessment lays the groundwork for a successful CMMC compliance strategy.
2. Develop a Compliance Roadmap
Once you’ve identified security gaps, create a structured plan to address them. Your compliance roadmap should include:
- Prioritizing essential security controls such as multi-factor authentication (MFA), endpoint protection, encryption, and network segmentation.
- Establishing a realistic implementation timeline based on your budget and available resources.
- Allocating funds for security tools, employee training, and external consulting if needed.
- Assigning clear roles and responsibilities to ensure each security control is implemented properly.
A well-organized roadmap keeps compliance efforts on track and prevents last-minute scrambling before the audit.
3. Implement Required Security Controls
Deploying technical and administrative controls is a critical step in CMMC readiness. Your focus should be on:
- Implementing all security controls required for your target CMMC level.
- Creating a System Security Plan (SSP) that details how each security requirement is met.
- Establishing incident response protocols, employee security training, and access management policies.
- Ensuring all cybersecurity measures are fully operational, tested, and documented before scheduling your assessment.
Proper security implementation not only strengthens compliance efforts but also reduces cyber risks within your organization.
4. Select and Prepare for a CMMC Assessment
To obtain certification, you’ll need a formal CMMC assessment conducted by a Certified Third-Party Assessment Organization (C3PAO). Preparing for this audit involves:
- Selecting a C3PAO with experience in your industry and certification level.
- Scheduling the assessment early to allow for any last-minute compliance adjustments.
- Organizing all required documentation, including audit logs, security training records, access control logs, and system configurations.
- Conducting an internal pre-assessment to verify compliance and address any remaining vulnerabilities before the formal evaluation.
A well-prepared assessment process increases your chances of passing certification on the first attempt.
5. Maintain Continuous Compliance
CMMC compliance doesn’t stop after certification. To sustain compliance and cybersecurity resilience, you should:
- Implement continuous monitoring tools to detect and respond to threats in real time.
- Conduct regular security audits and risk assessments to identify new vulnerabilities.
- Keep security documentation and policies up to date as requirements evolve.
- Train employees on security best practices through ongoing cybersecurity awareness programs.
For long-term compliance, many organizations partner with a Managed Security Service Provider or use compliance automation tools. A provider like BEMO can streamline CMMC maintenance, reduce administrative workload, and ensure your organization stays audit-ready year-round.
Now that you know how to prepare, the next step is understanding how long the CMMC certification process takes and what to expect during the audit.
How Can BEMO Help Your CMMC Compliance Journey
Achieving CMMC certification can be a complex and time-consuming process. BEMO simplifies compliance by offering fully managed and automated services, helping organizations meet CMMC requirements efficiently while ensuring long-term compliance.
Here’s how BEMO’s expert support can help your organization achieve CMMC certification without unnecessary delays.
Dedicated Compliance Engineer
BEMO assigns a Compliance Engineer to oversee your entire certification process. This expert coordinates weekly progress meetings, ensures all security measures align with CMMC standards, and guides your team through evidence collection and audit preparation. By having a dedicated specialist, your organization can avoid missteps that could delay certification.
Automated Compliance Monitoring
Maintaining compliance requires ongoing security oversight, which is why BEMO provides an automated monitoring platform that continuously tracks security controls, identifies compliance gaps, and alerts your team to potential risks. Instead of manually reviewing complex security frameworks, you get a centralized dashboard that provides real-time visibility into your security posture.
Audit Support and Penetration Testing
Passing a CMMC assessment is a rigorous process, and BEMO ensures you are fully prepared. The team partners with accredited third-party auditors to conduct pre-assessment reviews, helping you address compliance gaps before the formal evaluation. Additionally, BEMO coordinates penetration testing twice a year, conducting internal and external security tests to identify vulnerabilities and confirm remediation efforts.
Policy and Documentation Management
Creating and maintaining CMMC-required policies can be overwhelming, but BEMO simplifies this with a custom compliance policy handbook covering disaster recovery, business continuity, access controls, and security training. Employees must review and sign these policies to meet framework requirements, ensuring that cybersecurity practices are embedded into daily operations.
Ongoing Compliance Maintenance
Organizations must continuously review security policies, assess risks, and adapt to new threats. BEMO conducts quarterly compliance reviews to evaluate IT infrastructure, security practices, and operational policies, ensuring ongoing alignment with CMMC standards. This proactive approach prevents non-compliance issues before they become a problem for your organization.
Public Compliance Trust Page
BEMO can set up a public webpage to showcase an organization’s compliance achievements. This allows businesses to demonstrate CMMC certification to vendors, partners, and customers.
What Are the Key Differences Between CMMC 1.0 and CMMC 2.0?
If you're preparing for CMMC certification, you need to know how CMMC 2.0 differs from the original framework. The biggest change is that the number of compliance levels have been reduced from five to three, making it easier to determine which security requirements apply to your organization.
Instead of a complex, layered approach, CMMC 2.0 now aligns with established cybersecurity standards like NIST SP 800-171 and NIST SP 800-172, simplifying the compliance process and making it more predictable.
Another key update is the introduction of Plans of Action and Milestones (POA&Ms). Under CMMC 2.0, you can achieve conditional certification while addressing outstanding security gaps within a set timeframe. However, this flexibility comes with strict deadlines as critical security controls must be implemented upfront, and non-compliance after the deadline could result in certification revocation.
Also, temporary waivers may be available for mission-critical work, but this doesn’t mean you can avoid compliance altogether. You’ll still need to meet full certification requirements to continue working on DoD contracts long-term.
To ensure you're fully prepared, assess your current security posture, develop a clear compliance roadmap, and implement ongoing monitoring to avoid last-minute surprises during audits.
Is CMMC Compliance Worth the Investment?
If your organization works with the Department of Defense, CMMC compliance is a requirement. The first certification mandates take effect in early 2025, meaning you need to start preparing now or risk losing your eligibility for government contracts.
With certification taking anywhere from 12 to 18 months, waiting until the last minute isn’t an option. You’ll need to implement strict security controls, undergo third-party cybersecurity assessments, and establish continuous monitoring to ensure compliance.
Failing to meet these requirements can result in contract loss, financial penalties, and increased cybersecurity risks, which could damage your business’s long-term prospects.
Beyond compliance, investing in CMMC security controls strengthens your overall cybersecurity posture, reducing your risk of data breaches and cyberattacks. BEMO simplifies the process with structured, automation-driven compliance solutions, helping you implement the required controls efficiently, pass assessments without delays, and maintain long-term security.
Now is the time to take action. Secure your CMMC certification with BEMO’s expert guidance today.
Frequently Asked Questions about CMMC
How Do I Know Which CMMC Level My Organization Needs?
The required CMMC level depends on the type of data your organization handles. Companies dealing only with Federal Contract Information (FCI) typically require Level 1, while those handling Controlled Unclassified Information (CUI) need Level 2 or 3. Review your contract requirements and consult with a compliance expert to determine the appropriate level.
Can Small Businesses Afford CMMC Compliance?
While compliance costs can range from $50,000 to $500,000, small businesses can manage expenses by using compliance automation tools, prioritizing essential controls, and seeking cost-effective managed security services. Many primes and DoD programs also offer guidance and support to subcontractors.
Are There Penalties for Failing a CMMC Assessment?
Organizations that fail a CMMC assessment cannot bid on or retain DoD contracts requiring compliance. They must address deficiencies and undergo reassessment before certification is granted. Delays in compliance can also lead to business disruptions and lost revenue.
How Often Does CMMC Certification Need to Be Renewed?
CMMC certification is valid for three years. However, organizations must conduct annual affirmations and maintain continuous compliance through security updates, monitoring, and regular assessments to ensure they meet evolving DoD requirements.
Do Subcontractors Need to Be CMMC Compliant?
Yes, subcontractors must meet CMMC requirements if they handle FCI or CUI, even if they do not contract directly with the DoD. Prime contractors are responsible for ensuring their entire supply chain complies with the appropriate CMMC level.
Can My Organization Use a POA&M to Pass a CMMC Assessment?
Plans of Action and Milestones (POA&Ms) are allowed under CMMC 2.0 but only for non-critical security gaps. Organizations must close all POA&Ms within 180 days to maintain certification. Critical controls must be fully implemented before certification is granted.
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