CMMC Compliance Requirements: What Businesses Need to Know

Government agencies must protect national security, even when working with defense contractors. That's why they require Cybersecurity Maturity Model Certification (CMMC) compliance.

Here, we highlight the essential CMMC compliance requirements businesses must meet to protect sensitive data and achieve cybersecurity maturity certification.

The Core CMMC Compliance Requirements that Businesses Must Understand

CMMC is a set of measurable standards that the U.S. Department of Defense (DoD) sets for all corporations that work with the federal government, especially those in the defense sector. 

Here are the core CMMC compliance requirements businesses must understand and implement:

• Compliance Levels: Businesses should know the maturity level required for their operations. There are three CMMC levels (CMMC 2.0), each signified by the depth and complexity of its technological capabilities. Levels range from basic cybersecurity hygiene (Level 1) to very high maturity (Level 3).
• Safeguarding Information: Businesses must understand how to handle and protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) to meet security regulations as CMMC prescribes. This includes data encryption, secure data handling, transmission, and storage.
• Adequate Cybersecurity Practices: An organization handling defense contracts should implement the 17 core cybersecurity domains, such as access control, incident response, maintenance, risk management, security assessment, situational awareness, personnel security, recovery, etc.
• Self-Assessment: Companies should evaluate their own cybersecurity measures, identify areas of improvement, and work towards meeting their CMMC level demand based on self-assessment results.
• Implement a System Security Plan (SSP): Enforce an SSP that outlines your organization's approach to meeting CMMC requirements.
• Maintain System Security Inventory: Develop and maintain an inventory of all organizational systems that process, store, or transmit CUI.
• Continual Cybersecurity Improvement: Organizations should continuously develop and improve their cybersecurity posture, including establishing regular cybersecurity training for employees.
• Third-Party Assessment: Businesses must pass an evaluation by a certified independent assessor (known as C3PAO—Certified Third-Party Assessment Organization) to be certified at any level of CMMC (other than Level 1).
• Compliance Maintenance: After achieving certification, businesses should maintain and update their cyber defenses through regular audits and system updates, adhering to the requirements for each level.
  • Level 1: Requires annual self-assessment and affirmation of compliance with the 15 security requirements.
  • Level 2: Mandates the conditions below —
    • Requires either of the following (Determined by the type of information the contractor stores, processes, or transmits) —
      • An ordinary self-assessment.
      • Conduct a C3PAO assessment every three years, as specified in the solicitation.
    • An annual affirmation that verifies compliance with the 110 security requirements in NIST SP 800-171 Revision 2
  • Level 3: Requires the following criteria —
    • Attain CMMC Status of Final Level 2.
    • Every three years, the contractor must undergo an assessment by the Defense Contract Management Agency’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
    • Offer an annual affirmation verifying compliance, done with the 24 identified requirements from NIST SP 800-172.
• Legal Requirements and Exposure: CMMC certification is a compliance requirement for doing business with the DoD. Companies that fail to satisfy the needed level could face legal consequences.

Mandatory Practices and Processes Under CMMC 2.0 Model

The CMMC 2.0 version is meant to reduce the complexity of its predecessor. As a result, the simplified framework collapses the maturity levels from five to three, making the certification process more straightforward. 

This streamlined model also aims to reduce cost without compromising cybersecurity standards.  

Here’s a rundown of its key revisions and the expectations for each level:

1. CMMC Level 1: Foundational: 
   Like CMMC 1.0, this requires organizations to implement basic cybersecurity practices. However, unlike 1.0, organizations can perform these practices without documentation and on an ad hoc basis. Another salient difference is that organizations can achieve certification through annual self-assessment. 
   
   Those who require CMMC Level 1 are defense contractors that handle FCI. This is “Information not intended for public release, that is provided by or generated for the Government under a contract to develop or deliver a product or service to the Government.”
    
2. CMMC Level 2: Advanced:
   Unlike Level 1, which allows ad hoc processes, Level 2 requires contractors to document repeatable processes that guide their efforts to achieve certification. Since Level 2 is a progression between Level 1 and Level 3, it is often called intermediate cyber hygiene. Level 2 is also classified as advanced cyber hygiene practices.  
   
   On the previous CMMC 1.02 scale, the current Level 2 is equivalent to the last Level 3. This Level 2 comprises 14 domains and 110 practices (from CMMC 1.02) aligned with NIST SP 800-171. These include system maintenance, incident response, and access control.
   
   On the other hand, it eliminates 20 Level 3 practices from CMMC 1.02. While self-assessment is permitted for non-critical CUI, DoD contractors handling critical national security information require C3PAO assessment.
    
3. CMMC Level 3: Expert:
   This level is reserved for DoD contractors handling the most sensitive information. Level 3 requires enhanced security measures to mitigate sophisticated risks such as APTs. Due to the high level of security controls and scrutiny needed, government-led assessments are mandatory. 

Organizations must demonstrate both the technical ability to implement the necessary security controls and the procedural documentation indicating how these protocols are maintained.

How Can Companies Determine Which Maturity Level They Need to Comply With?

Determining the appropriate CMMC maturity level for an organization largely depends on the type of information the organization handles or processes. Here are the steps to help companies determine their maturity level:

• Identify the Information You Handle: The first step in determining the appropriate maturity level is understanding the kind of data your organization handles. If it handles only Federal Contract Information (FCI), Level 1 may be adequate. However, if your organization handles Controlled Unclassified Information (CUI), you may need a higher level of certification.
• Understand Contractual Obligations: The company should review its DoD contracts or seek clarification from the DoD contracting officer. The required level of CMMC will be stipulated in their contracts with the DoD or other federal agencies.
• Perform a Gap Analysis: Undertaking a gap analysis can help an organization understand where its current cybersecurity practices stand in relation to the requirements of each CMMC level.
• Consult with a Compliance Expert: Seeking the help of a compliance expert or advisor who knows the ins and outs of CMMC can provide tailored advice on which maturity level is most suitable for the company.
• Consider Future Goals: Organizations should also consider their future growth and expansion goals. If the company aspires to secure larger or more sensitive DoD contracts in the future, it may want to pursue a higher level of CMMC certification upfront.
• Balance Costs and Benefits: Achieving higher levels of CMMC certification can be costly. Therefore, organizations should carefully consider the costs and benefits associated with each level of certification. 

Keep in mind that achieving a certain level of certification isn't a one-time event. Instead, ongoing efforts are required to maintain that designated level of certification.

What Documentation Is Required To Demonstrate CMMC Compliance?

To demonstrate CMMC compliance, organizations are required to have a comprehensive set of documentation that outlines their cybersecurity practices, procedures, and policies. Here are some key documents:

• System Security Plan (SSP)
  This document provides a detailed overview of the organization's security requirements and how these requirements are met.
• Plan of Actions and Milestones (POA&M)
  This document shows how the organization plans to address its security weaknesses and the timeline for these actions.
• Incident Response Plan
  This document outlines the organization's plan to handle and respond to a cybersecurity incident.
• Audit Logs
  Records that show evidence of regular review of the logs to identify and respond to any suspicious activities.
• Access Control Policy
  This policy document specifies who can access different parts of the system and under what conditions.
• Risk Management Plan
  This document describes how the organization identifies and manages risks.
• Network Diagrams
  These diagrams visually represent the organization's network, including firewalls, servers, and data flows.
• User Training Records
  These records should prove that all the necessary cybersecurity policies and procedures training have been provided to those with access to CUI.
• Configuration Management Plan
  This document details how changes are managed in the organization's systems.
• Disaster Recovery and Business Continuity Plan
  These documents outline how the organization plans to recover from a disaster and maintain business operations.
• Policies and Procedures Document
  This details the organization's cybersecurity policies and procedures.

Each organization may have different documentation requirements depending on its specific circumstances and the CMMC level it is seeking to achieve. It's highly recommended that you work with a CMMC consultant or advisor to ensure all necessary documents are supplied.

How Compliance Requirements Under CMMC Align with Other Federal Cybersecurity Regulations

The Cybersecurity Maturity Model Certification (CMMC) combines several cybersecurity standards and best practices and maps them across several maturity levels that range from basic cybersecurity hygiene to advanced. 

Here's how CMMC aligns with other federal cybersecurity regulations:

1. NIST SP 800-171: Most of the practices and processes in the CMMC model (especially in Levels 2 and 3) are derived from the NIST SP 800-171 security requirements, which are designed to protect Controlled Unclassified Information (CUI) in non-federal systems and organizations.
2. DFARS 252.204-7012: The CMMC framework was designed to enhance the cybersecurity requirements in the Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012 for DoD contractors. Like the DFARS rule, CMMC aims to safeguard FCI and CUI.
3. Federal Information Security Management Act (FISMA): Though CMMC is more specific to the Department of Defense's contractors, it aligns with FISMA's broader objective of implementing comprehensive security standards to protect government information, operations, and assets against natural or manmade threats.
4. FedRAMP: While FedRAMP focuses on cloud services for federal agencies, some CMMC controls can map to FedRAMP controls as both aim to standardize security assessment, authorization, and continuous monitoring.

CMMC borrows many elements from other frameworks and standards to create a more complete and unified standard that aims to increase the security and integrity of the defense supply chain, not just compliance. 

However, compliance with CMMC does not guarantee compliance with other federal cybersecurity regulations, as each has its own specifics, so organizations may need to meet further requirements.

The Common Challenges Businesses Face in Meeting CMMC Compliance Requirements

Businesses may face several challenges while trying to meet CMMC compliance requirements. Here are a few common ones with potential solutions to overcome them:

• Understanding CMMC Requirements: Many businesses struggle to understand the complex requirements laid out in the CMMC framework.

Solution: Businesses should consider engaging a compliance expert or consulting firm experienced with CMMC requirements. They can also use online resources and training provided by the DoD.

• Resource Allocation: Implementing the security measures to pass a CMMC audit often requires substantial time, effort, and money. 

Solution: Comprehensive planning and budget allocation are crucial. Proper training can also help employees understand their roles in maintaining cyber hygiene, thus minimizing the chances of a costly data breach.

• Maintaining Compliance: Achieving CMMC compliance is not a one-time task. Regular monitoring and updates are required to remain compliant.

Solution: Businesses should invest in automated platforms to continually monitor and maintain compliance.

• Identifying Controlled Unclassified Information (CUI): Determining what information qualifies as CUI can be difficult, making it challenging to apply the necessary controls.

Solution: Consulting with experts or using automated identification tools can streamline the process. 

• Documentation: Proper and extensive documentation is required for CMMC compliance, which could be overwhelming.

Solution: Consider using compliance software that can help with creating, storing, and managing the necessary documentation. 

• Cost of Achieving Compliance: Fulfilling all CMMC levels can be expensive, especially for small and medium-sized businesses.

Solution: Businesses should conduct a cost-benefit analysis and strategically plan to mitigate these costs. Seeking out grants, setting up partnerships, or consulting with experts to implement only the necessary requirements can be helpful.

Fortra Understands How to Meet Stringent Cybersecurity Requirements

Achieving CMMC compliance requires organizations to properly identify, classify, and protect CUI throughout their systems. Data classification tools are essential for meeting CMMC requirements, as they can automatically discover sensitive data, apply appropriate security controls, and maintain the audit trails necessary for certification. Without robust data classification capabilities, organizations struggle to demonstrate compliance with CMMC's stringent data protection standards, putting their ability to work with the Department of Defense at risk.

Schedule a demo today to learn how Fortra Data Classification can deliver the capabilities your organization needs for proper compliance, all while keeping users productive.