Key Takeaways

1. CMMC 2.0 Simplifies Compliance but Strengthens Security: With the reduction from five to three maturity levels and a sharper focus on NIST standards, organizations must still meet rigorous CMMC 2.0 compliance requirements despite a streamlined framework.

2. Self-Assessments Are Limited; Third-Party Assessments Are Essential for Many: While all businesses can self-assess at CMMC Level 1 and some can self-assess at CMMC Level 2, most organizations handling CUI will require third-party certification to achieve CMMC 2.0 compliance.

3. Partnering with an Authorized C3PAO Accelerates Compliance and Reduces Risk: Working with an Authorized C3PAO helps organizations efficiently close security gaps, navigate regulatory complexities, and avoid costly assessment failures.

Does your organization do business with the Department of Defense (DoD)? If so, you’ve probably heard the buzz about upcoming Cybersecurity Maturity Model Certification (CMMC) 2.0 requirements.

First announced in November 2021, CMMC 2.0 is the latest evolution of the DoD’s cybersecurity framework designed to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) across the defense industrial base. It applies to all DoD contractors and subcontractors who will process, store, or transmit FCI or CUI in performance of a DoD contract. CMMC 2.0 acts as a streamlined version of previous regulations, simplifying compliance pathways while still maintaining rigorous security expectations.

Currently, the CMMC 2.0 program implementation date is set to begin 60 days after the publication of the final Title 48 CFR CMMC acquisition rule (CFR 48), which is actively moving through the comment resolution process and is under review by the Office of Information and Regulatory Affairs (OIRA). The DoD predicts that 48 CFR will begin appearing in contracts by Q2 2025. Once finalized, select contracts will begin requiring CMMC Level 1 and Level 2 self-assessments for applicable solicitations.

However, in anticipation of future bids, some prime contractors are already beginning to require subcontractors to self-attest to CMMC Level 2 compliance or undergo compliance assessments with a Certified Third-Party Assessment Organization (C3PAO) or the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). If you haven’t already started, now is a great time to begin aligning your cybersecurity practices with CMMC 2.0 standards.

In this post, we’ll break down the key differences between CMMC 2.0 and previous versions. We’ll also show how working with an Authorized C3PAO like IS Partners can accelerate your path to CMMC 2.0 compliance and what steps you should take next.

What Is CMMC 2.0 Compliance?

Whether you’re familiar with the original CMMC regulations or just starting your compliance journey, understanding the changes in CMMC 2.0 standards is critical to maintaining eligibility for lucrative defense contracts.

There are four key differences between CMMC 2.0 and earlier versions of the cybersecurity regulations.

Reduced Number of Maturity Levels: CMMC 2.0 simplifies and streamlines compliance for defense contractors by reducing previous certification levels from five to three. Level 1 is designed to protect FCI by aligning with FAR 52.204-21. Levels 2 and 3 protect CUI by aligning with NIST SP 800-171 and NIST SP 800-172 respectively.
Self-Assessments Allowed for Some Contracts: Organizations pursuing Level 1 CMMC 2.0 compliance (and some at Level 2) can perform annual self-assessments rather than requiring third-party certifications. This change lowers the barrier to compliance for small businesses while still mandating accountability for aligning with DoD cybersecurity best practices.
Alignment with NIST Standards: CMMC 2.0 emphasizes full alignment with existing federal cybersecurity standards, specifically NIST SP 800-171 and 800-172. This makes the framework more predictable and consistent with broader federal requirements.
Elimination of Maturity Processes and Practices: Unlike the original model, CMMC 2.0 removes the requirement for organizations to demonstrate institutionalization of processes. Instead, the focus is squarely on implementing required security controls.

Why Work with an Authorized C3PAO?

While some organizations can self-assess, most handling CUI will need a third-party assessment to achieve CMMC 2.0 Level 2 compliance. Here’s why engaging an Authorized C3PAO is critical:

Accelerate Your Compliance Timeline: Experienced C3PAOs understand the complexities of CMMC 2.0 compliance requirements and can help you navigate the process efficiently, avoiding costly delays.
Identify and Close Gaps Quickly: A C3PAO will conduct pre-assessments to uncover security gaps and guide you in implementing the necessary controls before your formal assessment.
Ensure Readiness for Upcoming Rulemaking: With the final rule for CMMC 2.0 standards expected soon, working with a C3PAO keeps you ahead of regulatory deadlines and ensures your organization is prepared to meet new contractual obligations.
Reduce Risk of Assessment Failure: Failed assessments can delay or even derail your ability to secure defense contracts. C3PAOs provide invaluable guidance to ensure you’re fully prepared before undergoing formal evaluations.

Don’t Wait to Start Your CMMC 2.0 Compliance Journey

The upcoming enforcement of CMMC 2.0 compliance requirements represents a significant shift for defense contractors and subcontractors. Whether you’re aiming for Level 1 self-assessment or preparing for a formal Level 2 certification, the time to act is now.

By partnering with an Authorized C3PAO and leveraging expert CMMC 2.0 compliance consulting, you can streamline your path to compliance, mitigate business risks, and stay competitive in the defense marketplace. IS Partners has a more than 95% client retention rate. We leverage decades of experience to deliver tailored CMMC compliance services that take your organization from the initial gap assessment through readiness preparation and straight into the compliance audit.

Ready to take the next step? Contact IS Partners today to learn how our team of Authorized C3PAO experts can help you navigate the complexities of CMMC 2.0 standards and accelerate your path to compliance.

A compliance consultant helps their client identify existing cybersecurity gaps and create a plan to meet CMMC 2.0 standards.

What Should You Do Next?

Conduct a Readiness Assessment Aligned with CMMC 2.0 Standards: Evaluate your current cybersecurity posture against NIST SP 800-171 and 800-172 to understand where you stand relative to the new requirements.
Engage a Trusted CMMC 2.0 Compliance Consulting Partner: If you’re handling CUI, start discussions with an Authorized C3PAO now to create a roadmap for successful certification before enforcement deadlines hit.
Monitor DoD Rulemaking Timelines and Prepare for Upcoming Enforcement: Stay informed about when CMMC 2.0 requirements will become mandatory for defense contracts, and ensure your compliance initiatives stay ahead of these deadlines.

It is important for organizations to have internal subject matter experts or leverage a third party like ISP to guide the organization’s understanding of NIST compliance. ISP provides virtual CISO services and NIST compliance audits to help organizations get a better understanding of the efforts needed to align with NIST requirements. Organizations should also ensure strategic goals are set and importance is placed on compliance efforts.
Jena Andrews, Director of Cybersecurity Services, IS Partners

Ready to secure your organization’s compliance with a tailored approach? Connect with us to set up a consultation today.

FAQs

Is NIST compliance mandatory for private companies?

NIST compliance is generally voluntary for private companies. However, many organizations choose to implement it because it provides a recognized standard of cybersecurity practices.

What are the key differences between NIST SP 800-53 and NIST SP 800-171, and which one should we follow?

NIST SP 800-53 and NIST SP 800-171 provide cybersecurity guidelines but are intended for different audiences. Federal agencies primarily use NIST SP 800-53 and include comprehensive security and privacy controls applicable to various information systems.
Meanwhile, NIST SP 800-171 is designed for non-federal organizations, especially contractors handling Controlled Unclassified Information (CUI)

What is a NIST Gap Analysis, and how can it help us prepare for compliance?

A NIST gap analysis is an evaluation process that assesses your current cybersecurity practices against the NIST standards. This analysis identifies areas where your organization’s existing controls fall short, highlights vulnerabilities, and provides a clear picture of what’s needed to achieve compliance.

Get a Quote Try our Compliance Checker

About The Author

Jena Andrews

Jena is a senior auditor and security consultant since 2021. She is specialized in compliance management, cybersecurity, IT security, and risk management. Jena is a certified information systems auditor (CISA) and project manager.

With a decade-long history in Project Management, Jena has focused the past five years on Compliance, IT and Operations auditing, Information Security, and Cybersecurity. She has conducted a plethora of compliance audits and security assessments in accordance with standards including SOC 1, SOC 2, HIPAA, PCI DSS, ISO 27001, and NIST 800-53, 800-171.

Jena is a proud B.S. graduate in Criminal Justice from West Chester University and holds esteemed CISA, PMP, and CCP certifications, further highlighting her expertise and commitment to professionalism.

Understanding SOC Compliance: Your Guide to Securing Client Data