Quick Answer: Many organizations assume CMMC is expensive because of the assessment itself. In reality, the biggest costs often come from poor scoping decisions made long before certification begins. In this episode of Trust Issues, Christina Reynolds, Registered Practitioner Organization leader and author of Scope Small, Win Big, explains how contractors can dramatically reduce compliance costs by understanding where Controlled Unclassified Information (CUI) actually resides, limiting their compliance boundary, and avoiding expensive technology mistakes.
Key Takeaways
- CMMC costs are often driven by poor scoping, not certification fees.
- Contractors should identify where CUI exists and determine whether it needs to be there.
- Allowing CUI to spread across multiple systems can significantly increase compliance costs.
- Building a smaller, well-defined enclave can reduce both complexity and expense.
- Non-FedRAMP authorized cloud solutions may create compliance challenges.
- The CMMC Phase 2 pause does not eliminate current compliance obligations.
- Proper scoping helps organizations focus resources on real risks instead of protecting unnecessary systems.
Table of Contents
- Why CMMC Costs Get Out of Control
- The Two Questions Every Contractor Should Ask
- How Commercial Tools Create Compliance Risk
- Why FedRAMP Matters
- The Phase 2 Pause Didn't Stop CMMC Requirements
- How Contractors Can Avoid Costly Mistakes
- Frequently Asked Questions
Why CMMC Costs Get Out of Control
When contractors talk about CMMC, conversations often include concerns about six-figure budgets and costly compliance projects.
Yes, while the audit is an investment and more expensive than other frameworks, say SOC 2 or ISO 27001 that range in the $10k-$20k compared to CMMC's $50k+, according to Christina Reynolds, the assessment itself is rarely the primary driver of those costs.
Instead, expenses often increase because organizations make scoping decisions before fully understanding where Controlled Unclassified Information exists within their environment.
When everything is treated as in-scope, every system, application, and process becomes part of the compliance effort. The result is a larger security boundary, more controls to implement, and significantly higher costs.
The key is understanding what actually needs protection before investing in compliance efforts.
The Two Questions Every Contractor Should Ask
Before beginning any major compliance initiative, Christina recommends asking two simple questions:
- Where is CUI present?
- Should CUI be present there?
Many organizations focus on the first question but overlook the second.
Just because CUI currently exists in a system does not mean it needs to remain there. Over time, sensitive information can spread into email platforms, file repositories, collaboration tools, engineering applications, and other business systems without a deliberate strategy.
When organizations fail to challenge those data flows, they often end up expanding the compliance boundary unnecessarily.
Understanding where CUI belongs is one of the most effective ways to control compliance costs.
The "Scope Small, Win Big" Approach
The philosophy behind Christina's book, Scope Small, Win Big, is straightforward.
The smaller the protected environment, the easier it becomes to secure, manage, maintain, and assess.
Organizations can often reduce compliance complexity by mapping data flows, removing unnecessary copies of CUI, and limiting protected information to systems specifically designed to handle it.
Rather than trying to secure the entire business, contractors can establish a focused enclave where sensitive information resides and where security controls can be more effectively managed.
This strategy often reduces implementation costs while improving compliance outcomes.
A well-defined scope allows organizations to spend money protecting what matters instead of expanding security requirements unnecessarily.
How Commercial Tools Create Compliance Risk
Scoping decisions do not only affect internal systems.
Software and cloud platforms can also create unexpected compliance challenges.
One of the first questions Christina asks prospective clients is whether they rely on commercial cloud services that may not meet CMMC expectations.
Organizations frequently assume that popular business tools are automatically compliant because they are widely used or because vendors advertise strong security capabilities.
However, familiarity is not the same thing as compliance.
When systems are improperly selected or incorrectly included within the compliance boundary, organizations may find themselves facing costly remediation projects later.
Technology decisions should be evaluated against compliance requirements before they become part of the CMMC environment.
Why FedRAMP Matters
For contractors handling Controlled Unclassified Information in cloud environments, authorization status matters.
A common challenge involves organizations using cloud platforms that are not aligned with the requirements expected for protecting federal information.
If an application or service falls inside the CMMC boundary, contractors must understand whether that solution is appropriate for handling sensitive government data.
Failing to validate cloud services early can lead to expensive migration projects, system replacements, or compliance remediation efforts down the road.
The lesson is simple: verify assumptions before building compliance plans around them.
The Phase 2 Pause Didn't Stop CMMC Requirements
Some defense contractors interpreted the CMMC Phase 2 pause as a reason to slow down cybersecurity investments.
Christina makes the case that this is a mistake.
Many compliance-related requirements continue to influence award processes, cybersecurity expectations, and contractor readiness efforts.
Organizations that delay preparation may find themselves rushing to address deficiencies later while competitors continue maturing their programs.
Rather than treating the pause as a stopping point, contractors can use the extra time to improve scoping decisions, strengthen controls, and eliminate unnecessary complexity.
The organizations that use this period strategically may be better positioned when future requirements resume.
How Contractors Can Avoid Costly Mistakes
CMMC does not have to become a budget-breaking initiative.
Many of the largest expenses occur when organizations implement controls broadly before understanding what actually requires protection.
A more effective approach is to:
- Map where CUI currently resides.
- Determine where CUI should reside.
- Remove unnecessary exposure where possible.
- Define a clear compliance boundary.
- Validate cloud and software decisions early.
- Focus resources on systems that genuinely require protection.
By starting with scope before technology purchases and implementation efforts, contractors can often avoid significant compliance costs while building a more sustainable cybersecurity program.
Ready to Reduce the Cost of CMMC Readiness?
A well-defined scope can make the difference between a manageable compliance project and an unnecessarily expensive one.
👉 Book a meeting with BEMO's compliance experts to review your CUI boundary, identify scoping opportunities, and build a cost-effective CMMC readiness strategy.
Want more practical insights from compliance practitioners and cybersecurity experts? Subscribe to the Trust Issues podcast for discussions on CMMC, NIST 800-171, cybersecurity strategy, and defense contractor readiness.
Frequently Asked Questions
Why do CMMC projects become so expensive?
Many projects become expensive because organizations define their compliance scope too broadly and attempt to secure systems that do not need to handle Controlled Unclassified Information.
What are the two most important scoping questions?
Organizations should determine where CUI currently exists and whether it truly needs to exist in those systems.
Why can cloud tools create CMMC challenges?
Choosing systems that do not align with compliance requirements can lead to remediation efforts, migrations, and increased implementation costs later.
Did the Phase 2 pause eliminate current compliance expectations?
No. Organizations still benefit from strengthening cybersecurity, improving readiness, and addressing gaps while additional time is available.
Why does scoping matter so much for CMMC?
Scoping determines which systems, users, processes, and technologies fall inside the compliance boundary. A smaller, well-defined scope generally results in lower costs, reduced complexity, and more efficient compliance efforts.
We've got more resources for you to become a cyber-pro.
Leave us a comment!