With the publication of the Final Rule under 32 CFR Part 170, the Department of Defense (DoD) has begun formally integrating Cybersecurity Maturity Model Certification (CMMC) requirements into defense contracts. Although full implementation will roll out over several years, the direction is clear: cybersecurity expectations across the Defense Industrial Base (DIB) are becoming more structured, more visible, and more enforceable. For contractors that handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), a CMMC assessment provides the DoD with a standardized way to evaluate whether required cybersecurity safeguards are consistently implemented and maintained. Rather than relying solely on self-attestations, the CMMC program introduces formal assessment mechanisms tied directly to contract eligibility.
As CMMC requirements phase into new contract awards and renewals, understanding how assessments are structured—and what readiness actually means in practice, has become increasingly important. This article outlines what defense contractors should know about CMMC assessment expectations in 2026 and how organizations are approaching readiness from a governance, documentation, and planning perspective.
Understanding CMMC Certification Levels and Assessment Requirements
The current CMMC framework organizes certification requirements into three levels, each based on the type of data handled and the associated cybersecurity risk.
Level 1 – Foundational
- Applies to organizations that handle Federal Contract Information (FCI) only.
- Includes 17 basic safeguarding practices aligned with FAR 52.204-21.
- CMMC assessments at this level are typically conducted through annual self-assessments.
Level 2 – Advanced
- Applies to organizations that handle Controlled Unclassified Information (CUI).
- Aligns with the full set of 110 security requirements in NIST SP 800-171.
- Depending on contract requirements, CMMC assessments may be completed via self-attestation or an independent third-party assessment (C3PAO).
Level 3 – Expert
- Reserved for contractors supporting the DoD’s most sensitive programs.
- Builds on NIST SP 800-171 with additional protections from NIST SP 800-172.
- Government-led CMMC assessments are required at this level.
Determining the appropriate certification level—and the corresponding assessment type—is primarily driven by contract language and the type of data handled, not by organizational size or industry.
Aligning CMMC Assessments with NIST SP 800-171
For many contractors, particularly those pursuing Level 2 certification, alignment with NIST SP 800-171 forms the foundation of CMMC readiness. This standard outlines 110 security requirements across 14 control families, covering areas such as access control, configuration management, incident response, and system communications protection.
With the release of NIST SP 800-171 Revision 3, organizations are paying closer attention to updated control definitions and expectations. While CMMC requirements reference specific versions in contracts and regulations, understanding how these controls evolve over time helps organizations maintain stronger governance and sustained compliance.
Many contractors find it valuable to regularly assess how existing policies, technical controls, and procedures align with NIST requirements, informing prioritization and planning for upcoming CMMC assessments. By mapping current practices to NIST SP 800-171, organizations can identify gaps early and build a structured readiness plan.
How CMMC Assessment Expectations Are Structured
CMMC assessments follow different pathways depending on the certification level and contract designation:
- Level 1 – Foundational: Conducted through annual self-assessments, with results submitted via the Supplier Performance Risk System (SPRS).
- Level 2 – Advanced: May require either a self-assessment or an independent third-party assessment (C3PAO), depending on whether the contract is designated as prioritized.
- Level 3 – Expert: Performed by the government through designated DoD assessment teams.
Understanding which assessment pathway applies, and when, is critical for realistic planning. Assessment requirements vary across contracts, and timelines are often driven by acquisition decisions rather than organizational readiness alone.
By knowing the expected assessment type for each level, contractors can better prepare for CMMC assessments, allocate resources effectively, and align internal policies, procedures, and technical controls with regulatory expectations.
CMMC Readiness as an Ongoing Governance Activity
Rather than treating CMMC as a one-time compliance exercise, many organizations are approaching CMMC readiness as an extension of broader cybersecurity governance. This approach supports sustained preparedness for CMMC assessments and includes:
- Maintaining current documentation of security policies, procedures, and practices
- Consistently implementing and monitoring technical controls across systems
- Aligning cybersecurity risk management with business objectives and contract requirements
- Planning for future changes as CMMC and NIST requirements continue to evolve
Organizations that adopt this governance-driven mindset typically experience less disruption when CMMC assessment requirements are introduced into active or upcoming contracts.
About This Article
This content is provided for informational and educational purposes only. It does not constitute legal advice, official certification guidance, or a determination under the CMMC program.
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