Organizations that want to contract with the Department of Defense (DoD) must achieve CMMC compliance. The Cybersecurity Maturity Model Certification (CMMC), governed by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)), establishes strict cybersecurity requirements for the Defense Industrial Base (DIB).
However, achieving CMMC compliance is not simple. The framework is comprehensive, structured, and maturity-driven — meaning organizations must implement both technical controls and institutionalized processes.
In this guide, we break down the top five challenges for CMMC compliance and how contractors can overcome them.
Challenge #1: Understanding Scope and Mapping Existing Frameworks
One of the biggest challenges in CMMC compliance is understanding the full scope of requirements — especially for organizations transitioning from other frameworks like NIST SP 800-171.
The CMMC framework consists of:
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17 cybersecurity domains
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171 practices
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43 capabilities
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Multiple maturity levels with increasing complexity
These domains include areas such as:
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Access Control
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Asset Management
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Incident Response
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Risk Management
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System & Communications Protection
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System & Information Integrity
For organizations already aligned with NIST SP 800-171, mapping controls can help accelerate readiness. However, CMMC introduces additional requirements, process maturity expectations, and formal third-party assessments.
Why this is difficult:
Many organizations underestimate the documentation, policy formalization, and evidence collection required for certification.
Challenge #2: Achieving “Cyber Hygiene” and Protecting CUI
A central milestone in CMMC compliance is protecting Controlled Unclassified Information (CUI).
This requirement aligns with DFARS Clause 252.204-7012 and corresponds to Level 3 under the original CMMC structure (now aligned with advanced protection requirements under CMMC 2.0).
Unlike traditional frameworks, CMMC uses a tiered maturity model:
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Basic practices
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Intermediate cyber hygiene
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Good cyber hygiene
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Proactive practices
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Advanced threat protection
To reach full “cyber hygiene,” organizations must implement:
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All 110 security requirements in NIST SP 800-171
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Additional CMMC-specific practices
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Documented and managed security processes
Why this is challenging:
Technical implementation is only half the battle. Organizations must demonstrate consistent execution, monitoring, and governance.
Challenge #3: Addressing Advanced Persistent Threats (APTs)
After achieving foundational protection for CUI, organizations pursuing higher levels of CMMC compliance must defend against Advanced Persistent Threats (APTs).
APTs are sophisticated, well-funded adversaries that:
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Continuously probe defenses
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Exploit subtle vulnerabilities
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Adapt tactics over time
Higher maturity levels introduce advanced practices focused on:
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Threat hunting
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Enhanced monitoring
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Proactive incident response
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Continuous improvement
Why this is difficult:
These practices require security expertise, tooling investments, and mature security operations capabilities — which many small and mid-sized contractors lack internally.
Challenge #4: Institutionalizing Security Processes
CMMC compliance is not just about implementing controls, it’s about institutionalizing them across the organization.
Each maturity level introduces increasing process expectations:
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Performed – Practices are executed
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Documented – Policies and procedures exist
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Managed – Processes are resourced and tracked
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Reviewed – Effectiveness is regularly evaluated
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Optimizing – Continuous improvement is embedded
Organizations must show that security is:
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Repeatable
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Sustainable
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Governed at the leadership level
Why this is challenging:
Process maturity requires executive buy-in, formal governance structures, documented workflows, and measurable KPIs.
Challenge #5: Obtaining Third-Party Certification
Unlike self-attested frameworks, CMMC compliance requires formal third-party assessment.
Organizations must be assessed by an authorized Certified Third-Party Assessment Organization (C3PAO). Certification is mandatory for most DoD contract eligibility.
This introduces additional challenges:
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Pre-assessment readiness gaps
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Evidence validation
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Audit preparation
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Risk of failing the assessment
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Budget planning for certification
Choosing a partner that provides both advisory and assessment support can significantly reduce risk and cost.
How to Simplify CMMC Compliance
CMMC compliance can feel overwhelming, but with the right strategy and guidance, it becomes manageable.
Successful organizations typically:
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Conduct gap assessments early
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Align with NIST SP 800-171 requirements
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Build documentation before assessment
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Implement governance processes
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Partner with experienced cybersecurity advisors
At RSI Security, we help contractors navigate every phase of the CMMC compliance journey — from readiness to certification and beyond.
If you’re preparing to compete for DoD contracts, now is the time to strengthen your cybersecurity posture and ensure compliance readiness.
Contact RSI Security today to begin your CMMC compliance journey.
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