CMMC Is a Business Decision: How to Build the Executive Case for Compliance

Why Executives Need to Pay Attention to CMMC

CMMC has moved from a future concern to a contracting reality. The DoD states that phased implementation of CMMC requirements has begun, with Phase 1 running from November 10, 2025, through November 9, 2026, focused primarily on CMMC Level 1 and Level 2 self-assessments.

While CMMC is often delegated to IT or security teams, the implications belong at the executive level. Skip Chapman, CISSP, C|CISO, Director of Government Programs at Fortra, framed it as a business decision:

“When evaluating CMMC as a no-go or go decision for your organization, the decision is actually quite simple. If your company handles FCI or CUI data, you must be CMMC compliant or you risk the loss of all of your DoD business.”

That is why the CMMC conversation should start with business exposure: current DoD revenue, future contract opportunities, prime contractor expectations, and the cost of losing eligibility.

The CMMC program is designed to assess defense contractor compliance with safeguarding requirements for FCI and CUI and provide increased assurance that contractors have implemented required cybersecurity standards. CMMC requirements are implemented through contracts, and DoD contractors and subcontractors entrusted with FCI or CUI must achieve a specific CMMC level as a condition of contract award where applicable.

That makes CMMC a leadership issue.

If your organization depends on DoD revenue, supports a prime contractor, handles controlled technical information, or plans to expand in the defense industrial base, CMMC readiness affects business continuity and growth.

How Do You Explain CMMC to Executives?

CMMC is a DoD cybersecurity verification program that affects whether contractors and subcontractors can win or retain certain defense contracts involving FCI or CUI. Executives should view CMMC as a revenue protection, risk management, and market eligibility initiative — not only as an IT compliance project.

The Wrong Executive Framing: “This Is an IT Checklist”

The fastest way to underfund CMMC is to frame it as an IT checklist.

Yes, CMMC includes technical controls. Yes, IT and security teams are central to implementation. But the program touches far more than technology:

• Contracts
• Sales pipeline
• Proposal strategy
• Legal obligations
• Procurement
• Supplier management
• HR and personnel processes
• Physical security
• Manufacturing operations
• Engineering workflows
• Cloud architecture
• Data governance
• Incident response
• Executive attestation
• Customer and prime relationships

CMMC readiness requires decisions about how the business handles sensitive government information. That is not something IT can solve alone.

The Right Executive Framing: “What Revenue Is at Risk?”

The executive conversation should start with revenue — and be sure to include sales leaders and business capture leaders in the conversation; they have a lot at stake.

Ask: 

• How much current revenue comes from DoD and civilian agency contracts?
• How much revenue comes indirectly through primes?
• Which contracts involve FCI?
• Which contracts involve CUI?
• Which future bids may require CMMC? Bear in mind that existing contracts can be modified at any time to include CMMC compliance requirements. The requirement begins when the modification is released.
• Which customers or primes are already asking about readiness?
• How much revenue could be delayed or lost if we are not ready?
• How much market opportunity depends on certification?

This reframes CMMC from “compliance cost” to “revenue protection.” 

For some organizations, the business case is straightforward: if a significant portion of revenue depends on DoD work involving CUI, CMMC readiness becomes a requirement for preserving that revenue stream.

For others, the decision may be more nuanced. If DoD revenue is small today but part of a growth strategy, CMMC may be an investment in future eligibility. 

“I always advise clients to start first and foremost with revenue. I mean, a business is a business, it’s there to make money. It’s there to obviously help the defense industrial base and further the mission, but at the end of the day, if you can’t make money, it can’t survive.” —Marc Zurcher, Managing Principal, Coalfire

CMMC Levels and Business Impact 

CMMC is tiered based on the type and sensitivity of information handled. The DoD describes CMMC as a tiered model with progressively advanced cybersecurity standards depending on FCI or CUI sensitivity.

At a high level: 

• Level 1 applies to basic safeguarding of FCI.
• Level 2 applies to organizations handling CUI and aligns with NIST SP 800-171 Revision 2 requirements under the CMMC program rule.
• Level 3 applies to higher-risk programs and includes enhanced requirements tied to NIST SP 800-172.

Executives do not need to know every control, but they do need to know which level applies to which business opportunities. 

The Cost Question: Why Scope Drives Budget 

CMMC compliance cost is not fixed. It depends heavily on scope.

If CUI is spread across the organization, the compliance burden grows. More systems, users, locations, and vendors may need controls and evidence. If CUI is contained in a smaller, well-governed environment, cost and complexity may decrease.

Under 32 CFR 170.19, the CMMC assessment scope must be specified before assessment. DoD Level 2 scoping guidance explains that asset categories inform the boundary for a CMMC assessment.

For executives, this means one of the best ways to control cost is to fund proper CUI discovery and scoping early.

A strong scoping effort can answer:

• Where does CUI actually live?
• Can we reduce unnecessary CUI sprawl?
• Can we create a CUI enclave?
• Which systems must be hardened?
• Which systems can be kept out of scope?
• Which vendors affect our boundary?
• Which workflows need redesign?

This is where compliance strategy becomes business strategy.

The Risk Question: What Happens If We Are Not Ready?

The risks of delaying CMMC readiness include:

• Lost contract eligibility
• Delayed awards
• Prime contractor pressure
• Increased remediation cost
• Assessment bottlenecks
• Scope surprises
• Inability to produce evidence
• Weak cybersecurity posture
• Contractual or representation risk

Executives also need to understand that government timelines are not the only timelines that matter. Prime contractors may impose earlier requirements on suppliers.

As Marc Zurcher warns:

“Just because the government has a set date for when they expect these requirements to be met does not mean that your primes that are part of your supply chain can’t ask you to meet these requirements earlier.” 

For suppliers, that means CMMC readiness can become a competitive requirement before a formal contract clause appears.

The DoD’s CMMC framework was created to strengthen defense industrial base cybersecurity and better protect DoD information from increasingly frequent and complex cyberattacks. That context matters. CMMC is not paperwork for its own sake. It is part of a broader effort to protect sensitive defense information.

The CMMC Leadership Alignment Problem

Many CMMC initiatives begin when a requirement lands on one person’s desk. That person may be in IT, security, compliance, or operations. They are told, “Go make us compliant.”

That approach rarely works.

CMMC readiness needs executive sponsorship because it requires cross-functional decisions. For example:

• Sales must identify affected opportunities.
• Contracts must identify clauses and flow-down obligations.
• Legal must evaluate representation risk.
• IT must define systems and controls.
• Security must monitor and enforce.
• HR must support personnel processes.
• Procurement must evaluate suppliers.
• Operations must adjust workflows.
• Finance must fund remediation.
• Executives must prioritize tradeoffs.

Without leadership alignment, the project becomes a series of disconnected tasks. With leadership alignment, it becomes a coordinated readiness program.

“CMMC is an organizational wide opportunity. I don’t even call it a problem. This needs to have alignment with sales, marketing, contracting, procurement, IT, really with all of their business processes. This needs to be something that is led from the C-suite down.” —Marc Zurcher, Managing Principal, Coalfire

How to Build the Executive Business Case

A strong CMMC business case should include six components.

1. Revenue exposure 

Quantify current and future revenue tied to DoD contracts and defense supply chain work.

2. Contract applicability

Identify which contracts involve FCI, CUI, DFARS obligations, or expected CMMC requirements. 

3. Required CMMC level

Determine whether Level 1, Level 2, or Level 3 is likely required for relevant work.

4. Current readiness

Summarize known gaps in data discovery, scoping, controls, documentation, and evidence.

5. Investment estimate

Estimate technology, advisory, remediation, staffing, training, and assessment costs.

6. Timeline and risk

Show how long readiness may take and which business risks increase if action is delayed.

The Fortra Practitioner Perspective

Fortra helps organizations connect CMMC readiness to business outcomes. That starts with data: identifying where CUI lives, defining a defensible scope, applying controls, and generating evidence that supports the system security plan (SSP).

This practitioner approach helps executives answer the questions they care about most:

• What revenue is at stake?
• What level do we need?
• What is in scope?
• What will it cost?
• What can we reduce?
• What evidence will prove readiness?
• What needs to happen first?

CMMC becomes more manageable when leadership understands that the program is not about buying a tool. It is about changing how the organization handles sensitive government information.

“We either do this or we lose this business. What do you want us to do?” —Skip Chapman, Director of Government Programs, Fortra

Executive CMMC Readiness Checklist

Use this checklist in leadership discussions:

• Identify current DoD and defense supply chain revenue.
• Identify future bids requiring FCI or CUI handling.
• Confirm likely CMMC level by contract type.
• Appoint an executive sponsor.
• Form a cross-functional CMMC steering group.
• Fund CUI discovery and scoping.
• Require a CUI data flow map.
• Review external service provider dependencies.
• Approve remediation budget.
• Establish an evidence collection plan.
• Track readiness milestones.
• Review progress monthly.