A CMMC gap assessment is the first step toward winning and keeping Department of Defense (DoD) contracts. It’s not just about passing an audit; it’s about proving your organization can safeguard the sensitive data that supports national security.
This proactive diagnostic identifies how closely your current cybersecurity posture aligns with the CMMC 2.0 framework and pinpoints the changes needed before you certify.
Finalized in December 2024 and enforced starting January 2025, CMMC 2.0 is now appearing in new DoD contracts. Knowing your compliance gaps now isn’t just smart—it’s a strategic advantage.
What is a CMMC Gap Assessment?
A CMMC gap assessment is a detailed evaluation of your current cybersecurity practices against the controls required under CMMC 2.0, which are based on NIST SP 800-171 (and SP 800-172 for higher-risk contractors).
It serves as a baseline to identify deficiencies, validate documentation, and prioritize remediation efforts—without the pressure of an official audit.
A typical gap assessment includes:
- Review of current security policies, processes, and documentation
- Technical control validation (via interviews, testing, or observation)
- Identification of implementation gaps and security control weaknesses
- Remediation roadmap with risk-based recommendations
Understanding CMMC 2.0 Levels
With the release of CMMC, the five-tier model was simplified to three compliance levels—each tied directly to federal cybersecurity standards.
Foundational – Level 1
- For organizations handling Federal Contract Information (FCI)
- 17 practices from FAR 52.204-21
- Annual self-assessments allowed
- Focuses on basic cyber hygiene (e.g., access controls, MFA, password policies)
Advanced – Level 2
- For organizations handling Controlled Unclassified Information (CUI)
- Implements all 110 controls from NIST SP 800-171
- Some organizations may perform self-assessments; most require C3PAO assessments
- Requires a formal System Security Plan (SSP) and Plan of Action and Milestones (POA&M)
Expert – Level 3
- For contractors exposed to advanced persistent threats (APTs)
- Includes select enhanced controls from NIST SP 800-172
- Requires a government-led assessment (via DIBCAC)
- Designed for organizations managing highly sensitive national security data
Why a CMMC Gap Assessment is Essential
The DoD doesn’t wait for organizations to “get ready”—certification is becoming a prerequisite for new contracts. A CMMC gap assessment helps ensure you’re prepared before a third-party auditor or DoD assessment team arrives.
Key Benefits:
- Pinpoints non-compliant practices and technical gaps
- Prepares your team for CMMC audits and interviews
- Accelerates POA&M and remediation planning
- Supports documentation readiness, including your SSP and related artifacts
- Improves overall NIST 800-171 alignment, regardless of assessment type
Gap assessments provide critical insight into whether your cybersecurity program is mature enough to pass a CMMC audit—and if not, how to fix it.
Common Deficiencies Discovered
Organizations often underestimate what’s required for CMMC certification. A gap assessment uncovers technical and procedural issues that could delay or derail compliance.
Some of the most common weaknesses include:
- Missing or outdated System Security Plans (SSPs)
- Lack of defined or enforced access control policies
- Incomplete or under-tested incident response plans
- Gaps in multi-factor authentication (MFA) deployment
- No formal risk assessment processes
- Inadequate training or security awareness programs
- Insufficient network segmentation or audit logging capabilities
Timeline: How Long Does It Take?
The duration of a CMMC gap assessment depends on your:
- Target CMMC level
- Cybersecurity maturity and documentation
- Size and complexity of your environment
- Availability of IT personnel and SMEs
For example, a company with 250 employees in a single office—handling CUI and targeting Level 2—can expect the gap assessment to take approximately 2 to 4 weeks.
Preparing for Your Gap Assessment
Preparation sets the tone for success. To maximize the benefits of a gap assessment, organizations should:
- Identify your CMMC Level target based on contract requirements
- Inventory your security documentation and begin compiling an SSP
- Review and familiarize yourself with the NIST SP 800-171 control families
- Engage a CMMC-AB Registered Practitioner or C3PAO partner for expert guidance
- Plan for remediation, including budget and personnel availability
CUI vs. FCI: Why It Matters
Understanding what type of data your organization handles is critical to determining your required CMMC Level.
- Federal Contract Information (FCI): Non-public info related to DoD contracts. Aligns with Level 1 and FAR 52.204-21.
- Controlled Unclassified Information (CUI): Sensitive data requiring additional protection, governed by NIST SP 800-171. Aligns with Level 2 or Level 3.
If you manage CUI—such as engineering drawings, defense schematics, or military research—you’ll need a more robust cybersecurity framework.
Trusted Advisory for CMMC Compliance
Understanding CMMC requirements is one thing—implementing them effectively is another.
RSI Security is a Registered Provider Organization (RPO) with the CyberAB, and our team includes multiple CMMC-AB Registered Practitioners (RPs) who specialize in helping defense contractors prepare for certification.
While we don’t conduct official audits, our role is just as critical: guiding your organization through the planning, implementation, and documentation needed to succeed.
From NIST SP 800-171 gap analysis to full CMMC readiness support, RSI Security delivers tailored, expert-driven advisory to help you meet your compliance goals—efficiently and with confidence.
Ready for CMMC? Let’s Close the Gaps Together
CMMC compliance is no longer just a future goal—it’s already here.
With the Final Rule now effective and official DoD assessments underway since January 2025, contractors must ensure they’re not left behind. A CMMC gap assessment is the first and most important step toward protecting national security, retaining contracts, and building a cyber-resilient business.
Get a clear roadmap to CMMC compliance, download our CMMC checklist and prepare for certification with confidence.
