The United States Department of Defense (DoD) handles some of the nation’s most sensitive information, making it a prime target for cyberattacks. Not only is the DoD itself at risk, but its extensive network of contractors and partners also faces serious cybersecurity threats. To protect national security, all organizations working with the DoD must meet strict cybersecurity standards. This is where CMMC Certification comes in. Soon, the Cybersecurity Maturity Model Certification (CMMC) will be mandatory for every DoD contractor, including the 300,000+ companies that form the Defense Industrial Base (DIB) and supply chain.
Understanding the challenges of attaining CMMC Certification is critical for companies that want to stay compliant and secure. Let’s explore the top obstacles and how organizations can prepare.
Top Challenges to Attaining CMMC Certification
The Cybersecurity Maturity Model Certification (CMMC) is a comprehensive framework that builds on existing cybersecurity standards to protect DoD contractors. Once fully implemented, CMMC Certification ensures consistent and robust security across all contractors, even across industries with vastly different IT environments.
However, achieving CMMC Certification is no small feat. While DoD contractors are already required to maintain cybersecurity measures, CMMC expands these requirements to create a higher standard of protection. It specifically focuses on safeguarding two critical types of sensitive data defined by the National Institute of Standards and Technology (NIST) Special Publication 800-171 and the Federal Acquisition Regulation (FAR) clause 52.204-21:
- Federal Contract Information (FCI): Data created by or on behalf of the federal government under contract, not intended for public access.
- Controlled Unclassified Information (CUI): Data that must be protected under legal or regulatory requirements, but is not classified.
Expanding cybersecurity measures to fully secure these types of data requires a detailed review of every system that processes or stores them. Unlike classified information, FCI and CUI can be more diverse and widespread, making compliance a complex and resource-intensive challenge.
This complexity is one of the primary hurdles companies face when pursuing CMMC Certification.
How Attaining CMMC Certification Works
Achieving CMMC Certification can be challenging, not just because of technical requirements, but also due to the process itself.
Previously, DoD contractors could self-assess and manage their cybersecurity internally. Under the new CMMC framework, however, a certified third-party assessment organization (C3PAO) is required to officially evaluate and certify your company.
What does this mean for your organization? You must prepare complete documentation and evidence that your business meets all required CMMC controls, whether independently or with external support. Only after review will an accredited C3PAO approve your organization for CMMC Certification, enabling you to contract with the DoD.
This external validation adds pressure and responsibility beyond traditional self-assessments. However, understanding exactly what your C3PAO is looking for, and preparing accordingly, is the key to successfully achieving CMMC Certification. Understanding the Level System
One of the key components of CMMC Certification is the level system, which breaks down the certification criteria into a series of graduated steps. Each level measures specific practices and processes essential to effective cyber defense.
The five CMMC levels are:
- Level 1 – Basic cyber hygiene: Practices are performed but not necessarily documented.
- Level 2 – Intermediate cyber hygiene: Practices are documented and repeatable.
- Level 3 – Good cyber hygiene: Practices are managed and institutionalized.
- Level 4 – Proactive practices: Practices are regularly reviewed and measured.
- Level 5 – Advanced/proactive practices: Practices are optimized for efficiency and effectiveness.
Each level builds on the previous one, cumulatively covering 171 practices. The complexity grows as processes increase in depth and scope, making CMMC Certification inherently challenging to achieve.
Successfully implementing each level requires careful planning, documentation, and ongoing management, which is why many organizations struggle without proper guidance.
Challenges at Each CMMC Level
Understanding the challenges at each level of CMMC Certification is critical for DoD contractors aiming for full compliance. The CMMC level system is designed to guide organizations through a step-by-step process, gradually increasing the rigor of cybersecurity protections until sensitive data is fully safeguarded.
Each level presents unique challenges, as companies must consistently apply specific practices and processes to achieve the intended outcomes. These outcomes can be grouped into four categories:
- Level 1: Safeguard all Federal Contract Information (FCI)
- Level 2: Transition to protection for Controlled Unclassified Information (CUI)
- Level 3: Fully protect CUI
- Levels 4–5: Implement preventative measures against Advanced Persistent Threats (APT)
Let’s break down the specific challenges that organizations face at each level and explore how they can successfully achieve CMMC Certification.
Level 1: Safeguarding Federal Contact Information
The simplest stage of CMMC Certification, making it an ideal entry point for organizations beginning their compliance journey.
Unlike higher levels, Level 1 primarily requires that cybersecurity practices are performed, rather than formally measured or documented. There are no specific quotas or benchmarks to meet. The requirements include:
- Processes: Performed – Practices must be executed, but process maturity is not measured. Level 1 focuses on ad-hoc or basic actions that form the foundation of cybersecurity.
- Practices: Basic Cyber Hygiene – 17 fundamental practices covering essential cybersecurity measures, such as proper data handling, indexing, and basic protective precautions.
Because Level 1 focuses on simply performing these basic practices, it serves as a straightforward first step toward achieving more robust CMMC Certification at higher levels.
Level 2: Transition to Protected Controlled Unclassified Information
where CMMC Certification requirements start to ramp up. At this stage, organizations prepare for the more stringent requirements of higher levels while implementing a significant number of new practices and introducing the first formal process maturity measures.
The requirements for Level 2 include:
- Processes: Documented – All practices, including the foundational ones from Level 1, must now be formally documented. This ensures that processes are repeatable, auditable, and ready for assessment by a C3PAO.
- Practices: Intermediate Cyber Hygiene – 55 new practices build on the initial 17 from Level 1, covering areas such as rigorous backup programs, user screening, and more detailed cybersecurity procedures.
One of the biggest challenges at Level 2 is managing the cumulative total of 72 practices (17 from Level 1 plus 55 new ones). In addition, the documentation requirement for all practices significantly increases the complexity of achieving CMMC Certification at this stage.
Level 3: Fully Protect Controlled Unclassified Information
where CMMC Certification becomes truly demanding. This level builds on the foundational work of Levels 1 and 2, marking the first stage where all NIST SP 800-171 requirements are fully implemented.
The requirements for Level 3 include:
- Processes: Managed – All practices are actively managed, with detailed planning, execution, and ongoing oversight of every practice introduced in the first three levels.
- Practices: Good Cyber Hygiene – 58 new practices are added at this level, covering the remaining NIST SP 800-171 protocols and other prescriptive measures, such as employee training, policy enforcement, and continuous monitoring.
At Level 3, the cumulative total reaches 130 practices, all of which must be performed, documented, and managed. The sheer volume and diversity of tasks introduce a depth and breadth of complexity not seen in the previous levels.
Successfully achieving Level 3 is critical: by this stage, organizations have implemented all basic reactive protections, safeguarding CUI against known threats. The next levels (4 and 5) focus on advanced proactive measures designed to defend against evolving cyber threats, including Advanced Persistent Threats (APTs).
Levels 4 and 5: Reduce Advanced Persistent Threats
Represent the most demanding stages of CMMC Certification. These levels are designed to protect organizations against cyber threats that bypass earlier protections, including emerging and unknown threats.
As technology advances, cybercriminals constantly adapt, requiring organizations to stay ahead with proactive and optimized cybersecurity measures.
Level 4 requirements include:
- Processes: Reviewed – All practices are subject to continuous review, with corrections applied whenever necessary.
- Practices: Proactive – 26 additional practices are introduced from expert guidelines beyond NIST, including detailed testing, analysis, and scenario planning for potential threats.
Level 5 requirements include:
- Processes: Optimizing – Continuous optimization is applied across all prior practices, ensuring processes evolve with emerging threats.
- Practices: Advanced/Proactive – At least 15 highly detailed practices are implemented, with ongoing research and development to anticipate and counter new threats.
Together, Levels 4 and 5 present dynamic, cumulative challenges. Unlike the first three levels, these final stages require ongoing analysis, optimization, and application of all 171 practices across the CMMC framework. The complexity grows with each additional process, creating a demanding compliance environment.
Given the intricacy of these levels, professional guidance is often essential for successfully achieving full CMMC Certification and maintaining long-term cybersecurity readiness.
Maximize Your Cyber defenses with RSI Security
Achieving CMMC Certification doesn’t have to be overwhelming, RSI Security is here to guide your organization every step of the way.
No matter the challenges outlined above, or any unique hurdles your business faces, our team will help you implement solutions tailored to your needs. Our CMMC advisory services include comprehensive assessments, training, and support to ensure your organization is fully prepared for certification. Once C3PAO accreditation becomes available, RSI Security will be certified to certify your organization.
But our expertise doesn’t stop with CMMC. RSI Security also provides a full suite of compliance and cybersecurity services, including PCI DSS, HIPAA, and other regulatory standards. Our proactive cyber defense assessments and optimization solutions go beyond legal requirements, keeping your business secure against evolving threats.
Protect your organization and simplify the path to CMMC Certification, contact RSI Security today to get started.
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