CMMC Controls for Contractors with the Cybersecurity Maturity Model Certification (CMMC) framework demand more than just ticking boxes—it requires deliberate, organized action from day one. For companies supplying to the Department of Defense or its primes, grasping what controls apply and how to implement them is central to both eligibility and cybersecurity strength. Building that foundation wisely sets them up for smoother audits and better outcomes.
Identify Whether Your Business Handles CUI or Just FCI to Define Your Baseline
Contractors must first determine whether they handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). FCI, under FAR clause 52.204-21, calls for basic safeguarding controls—this aligns with the CMMC Level 1 requirements. If the business handles CUI, the required baseline jumps significantly and shifts into the realm of CMMC Level 2 compliance. Recognizing this boundary early clarifies what set of CMMC controls apply.
Once the distinction is clear, contractors set their baseline posture based on scope and risk. That means documenting what information is FCI or CUI, where it lives, how it moves, and who touches it. This step ties directly into the CMMC scoping guide and helps organizations avoid a misclassified assessment scope—a frequent oversight that leads to Common CMMC challenges.
Map Your Control Scope to Nist Sp 800-171’s 110 Practices if You Handle CUI
For businesses handling CUI the roadmap pulls in the NIST SP 800‑171 standard, which outlines 110 cybersecurity practices across 14 families. These practices become the basis of the CMMC level 2 requirements—so mapping your control environment to them is mandatory. A clear mapping ensures alignment with what third-party auditors or a C3PAO will expect.
This mapping also uncovers which practices are implemented, which need remediation, and which may not apply (for example due to scoping decisions). This reduces risk of gaps during the actual audit. Firms offering compliance consulting often emphasise this alignment as the pivot between simply meeting CMMC compliance requirements and doing so sustainably.
Prioritize Documentation of Your Ssp and Poa&m to Solidify Control Transparency
Documentation underpins proof of implemented controls. Two cornerstone artifacts are the System Security Plan (SSP) and the Plan of Action and Milestones (POA&M). The SSP describes how you apply the practices and technical solutions; the POA&M tracks deficiencies and remediation steps. Auditors look for both to satisfy CMMC controls and verify an organisation understands its posture.
It’s easy to focus only on tools or configuration and ignore this paperwork. However, lacking clear documentation often triggers delays or non-compliance findings in the audit. A contractor should treat the SSP and POA&M as foundational evidence—not just internal aids. Consulting for CMMC teams will often begin by helping prepare these documents.
Conduct a Comprehensive Gap Assessment Across All Required Control Families
A gap assessment examines each control practice against the current implementation. Contractors should use this step to identify where they fall short across access control, incident response, system and information integrity, and other control families. This step aligns with many government security consulting engagements. It’s not just a checklist—it’s an actionable roadmap of what must be fixed or improved.
The gap assessment feeds directly into remediation planning and risk prioritisation. For example, a missing audit log capability may impact multiple control families and should surface early. Addressing such gaps pre-audit makes the official assessment less risky. Many common CMMC challenges originate from insufficient upfront gap work.
Institute Self-assessment Frameworks for Level 1 and Level 2 Readiness Stages
Organisations should not wait until the formal audit to test their readiness. For CMMC Level 1 requirements covering FCI, self-assessment annually is required. For CMMC Level 2—if allowed—some contracts allow self-assessment rather than full C3PAO review. Establishing a recurring self-assessment framework lets a business monitor compliance posture, refresh evidence, and train internal teams.
This stage reinforces control implementation and ensures that staff understand the processes, documentation, and tools used. It transitions readiness from a one-time project into an operational discipline. Firms engaged in consulting for CMMC often guide clients to treat self-assessment as the sprint before the audit, not a substitute for formal review.
Prepare Clear Evidence of Control Implementation Ahead of Third-Party Audits
When contractors move into a formal assessment phase—often involving a Certified Third-Party Assessor Organization (C3PAO)—they must present evidence that each claim of compliance is supported by artefacts, logs, screenshots, and procedures. The audit process demands more than statements about policy—it requires proof. Preparing these materials ahead of time reduces audit time, lowers cost, and improves pass rate.
Furthermore, when evidence is well organised and aligned to the control mapping (e.g., tied directly to the SSP and POA&M), auditor questions are shorter and discoveries fewer. Contractors offering CMMC compliance consulting often emphasise this step as one of the most frequently under-invested phases.
Ensure Flow-down Contract Clauses Link Your Subcontractors to Required Controls
Primary contractors are responsible not just for their own compliance but ensuring their supply chain adheres to the necessary controls. Flow-down clauses in contracts should clearly stipulate that subcontractors handling FCI or CUI also meet the applicable CMMC levels. These clauses tie subcontractors into the same control chain and reduce risk of scope leakage.
Without this, primes may find that subcontractors create non-compliance pockets—something the DoD and your primes will factor into contract awards. Engaging in consulting for CMMC often involves mapping subcontractor responsibilities, documenting agreements, and tracing evidence across the supply chain.
Schedule annual affirmation and re-certification where required by DoD Policy
Once compliance is achieved, the work doesn’t stop. For Level 1 and Level 2 contractors, the Supplier Performance Risk System (SPRS) requires annual affirmation of compliance, and full audits recur (every three years for many Level 2 organisations). Contractors should plan these cycles now so they aren’t caught by surprise later.
Setting a calendar for reassessment and affirmation ensures that control drift, new risks, or changes in the environment are captured. With evolving threats, periodic engagement—sometimes with a consulting partner—keeps the posture current and your eligibility secure.
This stepwise pathway helps organisations move from uncertainty to structured readiness. For help or managed security support, the firm MAD Security provides targeted services in CMMC compliance consulting and audits.
