Introduction
Many defense contractors believe they are “CMMC compliant” because they have implemented cybersecurity controls or aligned loosely with NIST SP 800-171. But under the Cybersecurity Maturity Model Certification (CMMC 2.0) framework, implementation alone does not equal compliance. True compliance means meeting all requirements for your designated CMMC level and, when required, undergoing an independent third-party assessment.
For CIOs, CISOs, and compliance officers, misunderstanding this distinction can be costly. Once CMMC clauses appear in your contracts, failure to meet certification requirements may result in lost eligibility or even false attestation risk under DFARS. This post breaks down what CMMC compliance really means, clarifies key terminology, and dispels common myths that could undermine your readiness.
Compliance vs. Certification: Understanding the Difference
Many organizations use “compliant” and “certified” interchangeably, but under CMMC 2.0, they have distinct meanings:
- CMMC Compliant: You have implemented all the practices and processes required for your target CMMC level (usually Level 2 or Level 3).
- CMMC Certified: You have undergone and passed a formal third-party assessment by an accredited C3PAO (Certified Third-Party Assessment Organization).
Why it matters: Only certification satisfies DoD contract requirements once CMMC language appears in solicitations. Being internally compliant is important, but without certification, you are not contract-eligible.
Risks if ignored: Contractors that claim compliance without proof risk disqualification or reputational harm if discovered during a DoD audit. False attestation can also lead to legal exposure under the False Claims Act.
Pro Tip: Consider starting with a readiness review to validate your compliance status before scheduling a formal audit. This helps identify documentation gaps, missing controls, and process weaknesses early. Explore Nexeris’s CMMC consulting resources for a deeper understanding of the process.
CMMC Levels 1–3: The Path to True Compliance
CMMC 2.0 defines three levels of maturity, each tied to specific standards and assessment types:
- Level 1 – Foundational: Protects Federal Contract Information (FCI). Contractors perform annual self-assessments and report results through the Supplier Performance Risk System (SPRS).
- Level 2 – Advanced: Aligns with NIST SP 800-171, requiring third-party assessments for contracts involving Controlled Unclassified Information (CUI).
- Level 3 – Expert: Based on NIST SP 800-172, with government-led assessments for programs involving critical national security data.
Why it matters: The vast majority of contractors will fall under Level 2, which mandates independent verification, not self-attestation.
Risks if ignored: Assuming self-attestation is enough can lead to disqualification once Level 2 contracts require official certification.
Pro Tip: Map each CMMC control to your existing NIST 800-171 framework and identify which areas may require external validation. Nexeris’s CMMC gap analysis services can help create a structured roadmap for closing deficiencies.
Myth #1: “We’re Aligned with NIST SP 800-171, So We’re Already Compliant.”
Alignment is not certification. While NIST SP 800-171 remains the technical backbone of CMMC 2.0, the CMMC framework formalizes assessment and enforcement.
Why it matters: The DoD designed CMMC to close the trust gap created by years of self-attestation under DFARS. Even if your organization has implemented NIST controls, CMMC introduces formal documentation and validation requirements.
Risk: Contractors who claim compliance without evidence risk being found non-compliant during audits, or worse, facing False Claims Act exposure.
Example: A contractor may have multi-factor authentication enabled but lacks documented procedures for account management. Under CMMC, both implementation and documentation are required for compliance.
Pro Tip: Maintain evidence for each control: system security plans (SSPs), Plans of Actions & Milestones (POA&Ms), and proof of ongoing monitoring.
Myth #2: “We Can Self-Attest for Level 2 Contracts.”
Under CMMC 2.0, only Level 1 contracts allow annual self-assessment. Level 2 requires third-party certification when handling CUI.
Why it matters: The DoD explicitly rejected self-attestation for Level 2 after years of inconsistent compliance verification.
Risk: Attempting to self-attest for Level 2 contracts will result in noncompliance and potential contract termination. Contractors could also lose eligibility for subcontracting opportunities with primes that demand CMMC verification.
Pro Tip: Schedule a C3PAO assessment well before deadlines. As certification demand increases, auditor availability will tighten. Early scheduling reduces last-minute pressure and allows time for remediation. For official guidance, review the DoD CMMC FAQs.
Myth #3: “If We Pass a One-Time Audit, We’re Set for Good.”
CMMC compliance is not static, it requires continuous monitoring and annual validation.
Why it matters: Cybersecurity maturity is an ongoing discipline, not a one-time achievement. Threats evolve, employees change, and controls degrade over time.
Risk: Falling out of compliance between assessments could jeopardize active contracts. The DoD and primes are increasingly requiring proof of continuous compliance to maintain eligibility.
Pro Tip: Establish a continuous compliance program that includes quarterly internal reviews, vulnerability scanning, and automated control monitoring.
Myth #4: “CMMC Only Applies to Large Prime Contractors.”
Every contractor and subcontractor in the Defense Industrial Base (DIB) that handles FCI or CUI falls under CMMC.
Why it matters: Supply chain security is a DoD priority. Primes are responsible for ensuring their subcontractors meet the same standards, creating a cascading compliance requirement.
Risk: Subcontractors that fail to achieve certification can be removed from contract pipelines, even if they don’t handle CUI directly. Primes are unlikely to take on the liability of non-compliant partners.
Pro Tip: Review your flow-down clauses and verify CMMC requirements early in the contracting process. Primes will increasingly require proof of certification before onboarding subcontractors.
Myth #5: “CMMC Is Just an IT Project.”
CMMC compliance extends beyond technology, it’s an organizational commitment involving leadership, HR, operations, and legal teams.
Why it matters: Many of the 110 practices in NIST SP 800-171 cover governance, policy management, and training, not just technical controls.
Risk: Treating compliance as an IT-only effort can lead to missing documentation, poor user awareness, and failed audits.
Pro Tip: Form a cross-functional compliance team that includes representatives from IT, HR, legal, and operations. Regular collaboration ensures technical safeguards align with documented policies and procedures.
Myth #6: “CMMC Doesn’t Affect Our Current Contracts.”
Some contractors assume that existing DoD contracts will remain unaffected. However, as renewals and new solicitations are issued, CMMC clauses are expected to appear widely.
Why it matters: Compliance preparation takes months, if not years. Waiting until your next renewal cycle could result in being unprepared for new requirements.
Risk: Losing eligibility for recompetes or modifications could immediately impact revenue pipelines.
Pro Tip: Treat compliance readiness as a strategic initiative. Review your contract forecast for the next 12–24 months and prioritize certification for any project handling CUI.
The Real Meaning of “CMMC Compliant”
To be CMMC compliant, your organization must:
1. Implement all required controls for your target level (e.g., NIST SP 800-171 for Level 2. Maintain documentation and evidence for every practice.
3. Pass an independent third-party or government-led assessment (depending on level).
4. Demonstrate continuous monitoring and annual validation.
5. Maintain an active culture of security awareness and accountability.
In short: True compliance means proving, not claiming, that your organization can protect DoD data to the standards required.
Pro Tip: Refer to CISA’s Cybersecurity Resources and the MITRE ATT&CK framework to map controls to real-world threats. This ties compliance directly to active defense.
Common Pitfalls That Undermine Compliance
Even well-intentioned contractors stumble during the certification process. Common issues include:
– Missing documentation or inconsistent evidence.
– Incomplete SSPs or outdated POA&Ms.
– Lack of user awareness training.
– Failure to maintain logs and monitoring records.
– Neglecting subcontractor compliance tracking.
Pro Tip: Build an internal audit cadence. Review 10–15 controls each month so your organization remains audit-ready year-round.
Building a Culture of Continuous Compliance
Achieving certification is only the beginning. Sustaining compliance requires organizational commitment, leadership buy-in, and ongoing investment.
Recommended best practices:
– Conduct regular tabletop exercises and incident simulations.
– Train staff on evolving DoD security requirements.
– Update your SSP whenever major system changes occur.
– Use automation to monitor compliance metrics in real time.
– Integrate compliance status into quarterly business reviews.
Example: A mid-size contractor integrated CMMC metrics into its executive scorecard. When leadership saw compliance scores trending downward, they reallocated resources to remediate gaps proactively, avoiding a failed re-assessment.
Conclusion: Compliance Is the Floor, Not the Ceiling
Achieving and maintaining CMMC compliance isn’t just about checking boxes, it’s about protecting your eligibility, reputation, and long-term contracts in the defense ecosystem. Misunderstanding what “CMMC compliant” really means can have serious consequences. With the final rule rolling out through 2028, clarity and early action are critical.
Defense contractors that take a proactive, organization-wide approach to compliance will not only meet DoD requirements but also strengthen their cybersecurity resilience against evolving threats.For additional resources, visit the DoD CMMC resource center or review Nexeris’s CMMC readiness library for guidance on audit preparation, policy development, and continuous monitoring.