If your business works with or plans to work with the U.S. Department of Defense or its contractors, CMMC Level 3 may be a contractual requirement for your organization. Level 3 is the highest level of CMMC, and introduces a higher bar to show that your security program can adequately protect Controlled Unclassified Information (CUI). 

At Rhymetec, our vCISOs guide companies through compliance readiness every day. We’ve created this CMMC Level 3 Checklist to help you understand the CMMC Level 3 requirements, identify gaps in your current security program, and how to prioritize remediation efforts prior to engaging a C3PAO for certification and pursuing your official government-led assessment.

With the right planning, CMMC Level 3 can be achieved without derailing business growth or overloading your internal teams. If you are unsure of which level of CMMC you need, check out our CMMC Compliance Checklist for Level 2 and our CMMC Level 1 Checklist, or contact our team today for direct, tailored guidance for your organization.


CMMC Level 3 Compliance Checklist: What Are The Steps?

**The CMMC Level 3 Assessment Guide (v2.13) is released by the DoD’s CIO office and provides specific requirements and processes for assessment. Level 3 applies to a narrow subset of contractors working on high-sensitivity DoD programs involving advanced or unique CUI. Organizations should use our checklist as a reference, but also be sure to review the official rule and guide directly while preparing for assessments by DCMA DIBCAC. 

CMMC Level 3, also known as the “Expert” level, applies to organizations supporting DoD programs involving highly sensitive or mission-critical CUI. It combines the full NIST 800-171 control set with even more safeguards, pulled from NIST SP 800-172. 

CMMC Level 3 Requirements

Step 1: Reach CMMC Level 2 

Your organization must complete a successful Level 2 CMMC assessment by a C3PAO before beginning Level 3. This ensures all 110 NIST SP 800-171 controls are implemented. Once you have fulfilled the requirements for your CMMC Level 2 checklist, you just need to fill in the remaining requirements for Level 3:

Step 2: Implement Necessary NIST SP 800-172 Controls

The next step is to implement selected NIST SP 800-172 controls. The DoD requires adding 24 additional controls from NIST SP 800-172, which are designed to protect CUI against advanced threats. Additionally, you will need to update your System Security Plan from Level 2 to describe how both the 110 base controls and the 24 additional controls are implemented.

Step 3: Defining Your Assessment Scope

Use the official Level 3 Scoping Guide to categorize which CUI-bearing assets and surrounding systems are in scope. You need to confirm that unrelated systems (such as public WiFI or non-CUI devices) aren’t included. 

Step 4: Undergo A Government-Led Assessment

Level 3 requires a government-led assessment by DCMA DIBCAC every three years, plus annual affirmations by the organization’s Affirming Official. The Level 2 (C3PAO) annual affirmation for the same scope must also continue.

The DoD’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)’s role in CMMC is to conduct assessments every three years for organizations that need CMMC Level 3. This leads us into Step 5:

Step 5: Maintain and Renew Your Certification

According to official DoD documentation, here are the certification requirements for CMMC Level 3: 

CMMC Level 3 Assessment Requirements

Source: U.S. Department of Defense

Level 3 DIBCAC certifications require renewal every three years, and organizations have to also submit confirmation of compliance every year. 

CMMC Level 3 Checklist: Timelines 

The time required to meet CMMC requirements varies depending on your organization’s size, industry, and whether or not you already comply with NIST 800-171 or a similar framework. Below are timelines to show what an average organization can expect for Levels 1, 2, and 3. 

Working with a vCISO can streamline the process and fast-track you to audit readiness. Rhymetec works closely with trusted auditing partners and can connect you with them for your assessment. 

**Note: The following timeline assumes that the organization will start with a gap assessment and follow a typical implementation plan. Organizations that are already aligned with NIST 800-171 can generally proceed faster. 

CMMC Level 3 Timeline (9-12 Months) 

Gap Assessment and Planning: 1-2 Months

Advanced Technical Controls and Procedural Controls: 6-7 Months 

Validation and Final Preparation For Your Assessment (2-3 Months)

CMMC Level 3 Timeline

**Note: Level 3 readiness can be accelerated if your organization has already implemented FedRAMP or other NIST-based frameworks. Organizations with complex cloud environments can require more time for controls such as segmentation and advanced logging. The support of a vCISO from the beginning can vastly speed things up!

What About Other Federal Regulations? FedRAMP and CMMC

Many organizations are unsure whether they need to meet CMMC, FedRAMP, or both:

"Being in a marketplace where we're working with a lot of cloud service providers and a lot of software application services, that's one of the most common questions we get. There are significant differences between the two frameworks, but there are also a lot of overlapping controls." - Metin Kortak, CISO at Rhymetec

CMMC applies to DoD contractors and subcontractors working with CUI or FCI, and maps directly onto the NIST SP 800-171 security controls. 

FedRAMP is designed for cloud service providers that offer IaaS, PaaS, or SaaS to civilian federal agencies. It is based on NIST SP 800-53, and uses impact-level baselines (Low, Moderate, and High). 

"If you are a cloud service provider and you are working with the Department of Defense, there is a likely chance you need to comply with both CMMC and FedRAMP. A lot of organizations in this position will choose to pursue FedRAMP first. If you comply with FedRAMP and you implement all of the controls, you're already implementing the majority of the controls you’ll need for CMMC. The remaining work for CMMC will be working with auditors and gathering documentation.” - Metin Kortak, CISO at Rhymetec

Both frameworks require foundational security measures, including access controls, incident response, and continuous monitoring. However, FedRAMP imposes a broader and deeper set of both technical and documentation requirements, especially around cloud-hosted services. 

The good news is there’s substantial overlap—especially at FedRAMP Moderate—but the organization is still responsible for meeting all NIST SP 800-171 Rev. 2 objectives across the CMMC scope. FedRAMP-authorized CSPs help, but you must still map, evidence, and assess controls for your environment.

Organizations that need both will often opt to do FedRAMP first, as they can then leverage that foundation to streamline CMMC compliance. For a deeper dive on the differences between these two federal frameworks (and how to determine which you need), check out our blog on CMMC vs. FedRAMP.

Advantages of Engaging A CMMC Consultant To Help Meet CMMC Level 3 Requirements (The Earlier, The Better!)

The higher levels of CMMC are complex. 

If you aren’t already compliant with the relevant NIST frameworks, compliance for Levels 2 and 3 will require implementing a massive amount of technical controls and corresponding documentation. For many companies, it simply isn’t feasible to manage all of this internally. 

This is where a virtual CISO (vCISO) comes in. A vCISO acts as a CMMC Consultant, working closely with your team to understand your environment and translating technical requirements into what you actually need to accomplish. 

In-House vs. Consultant Options For CMMC Compliance

Our vCISOs at Rhymetec support you throughout the entire CMMC preparation process. We conduct your gap assessment, carry out control implementation for the controls you need, finalize documentation, and serve as the main contact point for auditors on your behalf.   

**For information on our vCISO pricing options, check out our blog on vCISO pricing. 

Outsourcing the bulk of the work required for CMMC is helpful at any point in the compliance process, but is especially transformative during the initial stages. In our experience, especially partnering with startups to meet their compliance goals, working with a vCISO from the beginning allows you to turn an onerous process into a business enabler. 

An experienced vCISO will build a security program for your organization that not only meets CMMC and requirements but scales as your business grows. They understand exactly how to structure your compliance program to enable you to more easily meet additional or future requirements in your industry, and can connect you to the best auditing partners in your space. Contact us today to learn more.


Partner For Success: Work With Rhymetec + An Accredited C3PAO 

Meeting CMMC requirements is a complex process.

The good news is that you don’t have to do it alone. Our partnership with industry leader A-LIGN, an accredited C3PAO, gives you access to both the security legwork needed to meet requirements as well as certified assessment services. 

Together, we help organizations prepare for CMMC with confidence. Whether you are just getting started or finalizing your readiness for an assessment, we’re here to support your compliance journey with security expertise and a trusted C3PAO partner. 

C3PAOs are the only organizations authorized by the CyberAB to perform official CMMC assessments. Their involvement is essentially a must-have for any contractor aiming for certification. Meanwhile, as a Registered Provider Organization (RPO), Rhymetec works hand-in-hand with A-LIGN to help you prepare for that assessment. 

RPOs are approved to offer consulting and readiness support, and help you implement required controls, remediate gaps, and make sure your security practices and documentation align with CMMC standards. Together with A-LIGN, we are proud to offer this streamlined option for our clients.

About Rhymetec

Our mission is to make cutting-edge cybersecurity available to SaaS companies and startups. We’ve worked with over 1,000 companies to provide practical security solutions tailored to their needs, enabling them to be secure and compliant while balancing security with budget. We enable our clients to outsource the complexity of security and focus on what really matters – growing their business. Contact us today to get started.

In our recent CMMC webinar, we joined forces with Vanta and A-LIGN to discuss the updated CMMC 2.0 and what organizations should be doing now to meet the requirements. Morgan Kaplan, Director of USG Strategy & Affairs at Vanta, moderated a lively discussion between Metin Kortak, Rhymetec CISO, and Matt Bruggeman, Director of Federal Sales at A-LIGN. 

This Rhymetec CMMC Compliance Checklist for CMMC Level 2 is directly based on their discussion and pulls in expert insights from the webinar. Check out the recording of the full webinar here.

CMMC Rhymetec Webinar

First, What Is CMMC?

CMMC, or the Cybersecurity Maturity Model Certification, is the Department of Defense's approach to standardizing cybersecurity requirements across its supply chain. It protects Controlled Unclassified Information (CUI) by requiring contractors (and many subcontractors as well) to meet security practices based on the type of work and data they handle. 

As Rhymetec CISO Metin Kortak explained in our webinar:

"CMMC is a framework that's been developed by the US Department of Defense, and it really applies to anyone who's working with the Department of Defense and also processes, transmits, or stores controlled unclassified information. If you're processing that information and you're also working on direct contracts with the Department of Defense, or if you're one of their subcontractors, that means CMMC might apply to you." - Metin Kortak, CISO at Rhymetec

That scope includes contractors, manufacturers, software vendors, and cloud service providers that deal with DoD contracts even indirectly. This Rhymetec CMMC Compliance Checklist breaks down what's required and how to build a roadmap that aligns with contract timelines for CMMC Level 2. (If you need CMMC Level 1, check out our CMMC Level 1 Checklist).

You can also contact our team today and we'd be happy to walk you through everything you need to know. 


Contact

How Does The Updated CMMC Version 2.0 Differ From The Original Version 1.0?

CMMC 2.0 simplifies the framework while reinforcing its core goal to protect sensitive data within the Defense Industrial Base (DIB). The shift from Version 1.0 to 2.0 reflects feedback from industry stakeholders who found the original model extremely onerous to implement:

"CMMC 1.0 was quite strict and required organizations to go through many additional requirements outside of NIST 800-171. This made the process extremely difficult, especially for organizations that need to comply with other government compliance frameworks such as FedRAMP. Based on the feedback received, 2.0 is a less strict version of CMMC, while still maintaining the core security requirements.” - Metin Kortak, CISO at Rhymetec

CMMC 1.0 introduced five maturity levels and included additional practices and documentation beyond NIST 800-171. This generated a lot of confusion for subcontractors and SaaS providers, especially those also working toward FedRAMP.

CMMC 2.0 successfully restructured the model around three levels and removed the unique CMMC-only requirements. The new version falls under basic safeguarding practices and are derived from the Federal Acquisition Regulation (FAR) 52.204-21, which directly references and relates to NIST SP 800-171 as part of its requirements.

This change reduces redundancy and increases compatibility with other federal frameworks. With the updated version, CMMC consultants have seen renewed customer interest: 

"In the past, in terms of the requirements themselves, it's been more around NIST 800-171, plus a couple of other CMMC requirements. Recently, there have been updates to the CMMC framework. They've updated from Version 1.0 to 2.0. We've seen a lot of interest from our customers about this new version of CMMC." - Metin Kortak, CISO at Rhymetec

This renewed interest is likely since the assessment requirements have evolved. The new version maintains some elements of the previous requirements, but refines the role of C3PAOs  (Certified Third Party Assessor Organizations): 

"C3PAOs come in and assess you against the requirements, depending on the level that you're at. Our goal is to validate that the sensitive data is actually being protected, because looking historically at just relying on self-attestations to 800-171 for anybody within the supply chain has not been sufficient." - Matt Bruggeman, A-LIGN

In short, CMMC 2.0 is:

  1. Better aligned with existing industry standards.
  2. Highly adaptable to real-world constraints.
  3. More accessible for businesses supporting DoD missions.

Getting Started: Determining Which Level You Need and A Gap Assessment

Before you get started on working through your CMMC compliance checklist (for whichever level you need), it’s important to understand what type of data your organization handles. 

This will determine which certification level of CMMC applies to your business:

"The first thing is understanding what type of data you process. If you don't know that, working with a partner to help you determine that can be helpful, because that's going to help you figure out which level of compliance you're going to need to do for CMMC." - Metin Kortak, CISO at Rhymetec

Determining Which Type of Organization Your Organization Handles

Two main types of information matter when it comes to CMMC:

  1. Federal Contract Information (FCI): Any information provided by or generated for the government under a contract that’s not intended for public release. Include project timelines, internal communications, and organizational charts related to a DoD contract.  
  2. Controlled Unclassified Information (CUI): More sensitive than FCI. This is information that the government has decided needs to be protected, but doesn’t meet classification levels such as “Secret” or “Top Secret”: 

“CUI is sensitive information that does not meet the criteria for classification but must still be protected. It is Government-created or owned UNCLASSIFIED information that allows for, or requires, safeguarding and dissemination controls in accordance with laws, regulations, or Government-wide policies.”  - Department of Defense

Examples of CUI include software code related to defense programs, incident response reports, training content, documentation for DoD systems, and API guides that define how systems interoperate with DoD environments. 

So, which CMMC Level Do You Need?

Based on the type of data your organization handles, there are three levels of CMMC:

Which CMMC Level Do You Need

Getting Started: Conducting A Gap Assessment 

Once you’ve identified which level applies to your organization, the next step is a gap assessment.

"For the next step, at Rhymetec, we always start with a gap assessment. A gap assessment against the NIST 800-171 controls is a must-have…It helps you determine if you have any missing controls or if you have any gaps in your compliance, so you can start putting together a roadmap for completing the remaining controls." - Metin Kortak, CISO at Rhymetec

The aim is to compare your current environment against the required controls. This process tells you what needs to be done before you’re ready to self-attest or move into the certification phase. 

CMMC 2.0 also allows you to use a Plan of Action and Milestones (POA&M) to formally track missing controls and your plan for implementing them:

“In 2.0, CMMC came out with a final action and milestones plan. This document essentially allows you to create implementation plans for controls that are missing in your gap assessment, so that you can remediate these controls within a certain amount of time. This is also something you can work with third parties on or conduct your own self-assessment.” - Metin Kortak, CISO at Rhymetec

Next, we'll break down what you need to do for each level of CMMC: 

CMMC Compliance Checklist: What Are The Level 2 Requirements?

CMMC Level 2 applies to organizations that process, store, or transmit CUI as part of their work with the Department of Defense. This includes software vendors, MSPs, and subcontractors that handle technical data, system specifications, or any other sensitive project-related information:

"If you process CUI as part of your work in the supply chain of the DoD, that's where the Level 2 requirements come in. A majority of organizations that handle CUI will require a third-party audit and CMMC certification." - Matt Bruggeman, A-LIGN

Level 2 is based on the controls in NIST SP 800-171. 

These controls are grouped into areas to include access control, configuration management, incident response, and audit and accountability. For a more comprehensive list of the 110 controls (with more technical detail), see the NIST SP 800-171 official documentation here. 

Below is a checklist with the main items broken down into three categories to give you an idea of what to expect:

1. Documentation and Assessment

Complete a full NIST 800- 171A self-assessment (or third-party assessment).

This will show which controls your organization is missing or needs to improve, and form the foundation for remediation work needed for CMMC.

Develop a System Security Plan (SSP).

The SSP documents how your organization has implemented each NIST control and serves as the core evidence package when it comes time for your external assessment by a C3PAO.

Create a Plan of Action and Milestones (POA&M) for any discovered gaps.

The purpose of a POA&M is to outline the timelines and resources needed to remediate security control deficiencies you discovered during the self-assessment.

Submit or update your SPRS score.

The Supplier Performance Risk System (SPRS) score is an indication of how many of the 110 controls you've implemented, and is required by DoD contracting officers when evaluating vendor eligibility.

Document CUI data flows.

Mapping how CUI moves through your systems (and your vendors) is a core part of scoping your security boundary and making sure this is documented in your compliance program.

2. Core Implementation Areas

Access Control.

Enforce measures to include least privilege and MFA, and manage privileged accounts.

Asset Management.

Inventory CUI systems, segment networks, and label systems appropriately.

Audit and Accountability.

Retain records and review logs for anomalies.

Configuration Management.

Establish secure baseline configurations and change control procedures.

Identification and Authentication.

Make sure your organization is using strong authentication mechanisms and unique IDs for users.

Incident Response.

Create an incident response plan if your organization doesn't already have one, and test it.

Maintenance.

Track system maintenance activities.

Media Protection.

Create policies to limit and monitor removable media and sanitize storage before reuse.

Personnel Security.

Screen employees, terminate access promptly, and deliver regular security training.

Physical Protection.

Restrict physical access to systems and facilities handling CUI.

Risk Assessments.

Perform risk assessments and remediate vulnerabilities.

Security Assessment.

Conduct internal control testing and prepare for external audits.

System and Communications Protection.

Implement boundary defenses and encryption for CUI in transit.

System and Information Integrity.

Deploy measures to include endpoint protection, monitoring for malware, and regular patching.

3. Third-Party Certification

Most organizations at Level 2 will be required to undergo an audit by a CMMC Third Party Assessment Organization (C3PAO). 

Some contractors (specifically, those working on lower-risk programs) might be permitted to self-attest for Level 2, but this is an exception.

C3PAOs validate the implementation of the 110 controls. Generally, you can expect them to conduct technical testing, interview your staff, and verify documentation. 

Preparing for Level 2 requires an enormous amount of coordinated effort across technical and operational domains. Working with a CMMC Consultant can vastly streamline the process for you.

CMMC Compliance Checklist: Level 2

CMMC Compliance Checklist: Level 2 Timelines 

The time required to meet CMMC Level 2 requirements varies depending on your organization’s size, industry, and whether or not you already comply with NIST 800-171 or a similar framework. 

Below are timelines to show what an average organization can expect for CMMC Level 2.

**The following timeline assumes that the organization will start with a gap assessment and follow a typical implementation plan. Organizations that are already aligned with NIST 800-171 can proceed faster. 

CMMC Level 2 Timeline (6-8 Months)

Gap Assessment and Planning (1-2 Months)

Control Implementation (3-4 Months)

Documentation and Internal Validation Prior to Audit (1 Month)

C3PAO Audit (1 Month)

**Note: A vCISO can streamline the process and fast-track you to audit readiness. Rhymetec works closely with trusted auditing partners and can connect you with them for your assessment. 

CMMC Compliance Checklist: Level 2 Timelines

Advantages of Engaging A CMMC Consultant (The Earlier, The Better!)

The higher levels of CMMC are complex. 

If you aren’t already compliant with the relevant NIST frameworks, compliance for Level 2 will require implementing a massive amount of technical controls and corresponding documentation. For many companies, it simply doesn’t make sense to try to manage all of this internally. 

This is where a virtual CISO (vCISO) comes in. 

A vCISO works closely with your team to understand your environment and translates CMMC requirements into what you actually need to accomplish. 

Our vCISOs at Rhymetec support you throughout the entire CMMC preparation process. We conduct your gap assessment, carry out control implementation for the controls you need, finalize documentation, and serve as the main contact point for auditors on your behalf.   

**For information on our vCISO pricing options, check out our blog on vCISO pricing. 

Outsourcing the bulk of the work required for CMMC is helpful at any point in the compliance process, but is especially transformative during the initial stages. In our experience, especially partnering with startups to meet their compliance goals, working with a vCISO from the beginning allows you to turn an onerous process into a business enabler. 

In-House vs. Consultant Options For CMMC Compliance

An experienced vCISO will build a security program for your organization that not only meets CMMC and requirements but scales as your business grows. They understand exactly how to structure your compliance program to enable you to more easily meet additional or future requirements in your industry, and can connect you to the best auditing partners in your space. 

Partner For Success: Work With Rhymetec + An Accredited C3PAO 

Meeting CMMC requirements is a complex process.

The good news is that you don’t have to do it alone. Our partnership with industry leader A-LIGN, an accredited C3PAO, gives you access to both the security legwork needed to meet requirements as well as certified assessment services. 

Together, we help organizations prepare for CMMC with confidence. Whether you are just getting started or finalizing your readiness for an assessment, we’re here to support your compliance journey with security expertise and a trusted C3PAO partner. 


C3PAOs are the only organizations authorized by the CyberAB to perform official CMMC assessments. Their involvement is essentially a must-have for any contractor aiming for certification. Meanwhile, as a Registered Provider Organization (RPO), Rhymetec works hand-in-hand with A-LIGN to help you prepare for that assessment. 

RPOs are approved to offer consulting and readiness support, and help you implement required controls, remediate gaps, and make sure your security practices and documentation align with CMMC standards. Together with A-LIGN, we are proud to offer this streamlined option for our clients. Contact us todayto learn more.

Over 80% of breaches involve weak or misused credentials, according to Verizon’s Data Breach Investigations Report. This is a clear example of just one risk that represents both a security and a compliance risk for organizations, as it impacts everything from the efficacy of your cybersecurity program to compliance audits, contracts, and revenue. 

For federal contractors handling Federal Contract Information (FCI), CMMC Level 1 directly addresses this risk and other pressing ones. Level 1 is designed to encourage basic cyber hygiene, and outlines 15 controls that help safeguard sensitive data and maintain eligibility for federal contracts.

In this blog post, we will go over a CMMC Level 1 checklist and requirements, starting with which types of organizations Level 1 applies to:  

Government contractors, subcontractors, and suppliers in the federal supply chain that handle FCI (Federal Contract Information) likely fall into CMMC Level 1. This tier is designed for contractors and subcontractors working with the Department of Defense who don't store or process sensitive technical data but still have access to basic contract details, for example.

CMMC Level 1 has 15 requirements. Your organization must meet these 15 requirements and self-attest against them each year. The requirements fall under basic safeguarding practices and are derived from the Federal Acquisition Regulation (FAR) 52.204-21. 

Below is our CMMC Level 1 Checklist, starting with the gap assessment process and then walking you through the 15 requirements that need to be addressed: 

Getting Started - CMMC Level 1 Checklist: Gap Assessment

"At Rhymetec, we always start with a gap assessment. A gap assessment against the NIST 800-171 controls is a must-have…It helps you determine if you have any missing controls or if you have any gaps in your compliance, so you can start putting together a roadmap for completing the remaining controls." - Metin Kortak, Rhymetec

The aim is to compare your current environment against the required controls. This process tells you what needs to be done before you’re ready to self-attest or move into the certification phase. 

CMMC 2.0 also allows you to use a Plan of Action and Milestones (POA&M) to formally track missing controls and your plan for implementing them:

“In 2.0, CMMC came out with a final action and milestones plan. This document essentially allows you to create implementation plans for controls that are missing in your gap assessment, so that you can remediate these controls within a certain amount of time. This is also something you can work with third parties on or conduct your own self-assessment.” - Metin Kortak, Rhymetec

Next, we'll break down what you need to do to meet the requirements of CMMC Level 1.

CMMC Level 1 Checklist

CMMC Level 1 Checklist

If your organization handles only FCI and not CUI, then CMMC Level 1 likely applies to you. 

"If you're only handling FCI and not CUI, you fall into Level 1. Level 1 is an order of magnitude less involved than Level 2. It actually only has 15 requirements that are heavily aligned with a subset of the NIST 800-171 framework. You must meet these 15 requirements, and then you just need to self-attest against them each year." - Matt Bruggeman, A-LIGN

This tier is designed for contractors and subcontractors working with the Department of Defense who don't store or process sensitive technical data but still have access to basic contract details, for example. The 15 requirements fall under basic safeguarding practices and map to NIST 800-171, Rev. 2, specifically from Federal Acquisition Regulation (FAR) 52.204-21. 

Below are the 15 action items you need to address for CMMC Level 1, divided into clear sections based on our expert advice. 

*For a full list of these items with a greater level of technical detail, see the official FAR 52.204-21 documentation. 

Access Control

1. Limit system access to authorized users.

To reduce the risk of unauthorized exposure of data, only users with a business need should be able to log in to systems that store or process FCI. 

In practice, what you’ll need to do is action items such as setting up role-based access controls, implementing IAM (identity and access management) tools, and regularly auditing user access to remove accounts if they are no longer needed. 

These types of security measures entail broader business benefits, as they reduce the risk of insider threats and limit the extent of potential damage in case of compromised credentials.

2. Limit system access to authorized devices.

Even if a user is not authorized, their device might be without the proper controls.

All laptops and mobile devices connected to your systems should be managed to prevent untrusted endpoints from introducing threats. Implementing Mobile Device Management or endpoint detection and response solutions are industry-standard methods to accomplish this and prevent threats from entering through untrusted endpoints.

3. Control access to system functions (e.g., user roles).

Users should only be able to perform actions appropriate for their job (such as admin tasks being restricted to IT staff). It is critical to define roles and assign permissions accordingly, and restrict admin rights to select personnel. 

These measures vastly minimize the risk of unauthorized changes or even accidental misconfigurations being made.

4. Verify control connections to external systems.

Any systems that link with a third party (such as a cloud storage provider or file-sharing services) can become gateways for data leaks. As such, they must be reviewed and approved to prevent unauthorized data transfers. 

Organizations can accomplish this by maintaining an inventory of all third-party connections, reviewing and approving integrations before use, and monitoring data flow between internal systems and external services. This serves to protect against data loss via insecure APIs or file-sharing platforms.

Identification and Authentication

5. Require user identification before granting system access.

Every action should be traceable to an individual. 

Action items to accomplish this objective include assigning unique user IDs to all personnel, eliminating any shared accounts, and enabling logging to tie activity back to specific users. 

The business value of this step is crucial, as it creates accountability and aids in forensic investigation in case of incidents.

Media Protection

6. Sanitize or destroy media containing FCI before disposal.

Leaving data on discarded devices is a common but extremely preventable risk.

Simply establishing a process to wipe drives using certified tools, physically destroy storage devices when decommissioned, and document sanitization or destruction (for audit purposes) accomplishes this and prevents data leakage from improperly discarded hardware.

7. Protect FCI stored on removable media and external drives.

Portable storage can create unique risks when used off-site, and it’s critical to protect data in the event devices are lost or stolen.

Avoiding the use of removable media altogether is the best way to circumvent this risk entirely, but if your organization has to use removable media, you should be encrypting USB drives and external hard drives and locking physical storage devices when not in use.  

Physical Protection

8. Limit physical access to systems storing or processing FCI.

Unauthorized individuals shouldn’t be able to walk up to a server or terminal. 

Acceptable measures to fulfill this requirement under CMMC Level 1 include using keycards, biometric access, or badge systems, monitoring entry points with surveillance, and keeping visitor logs. All of these measures greatly reduce the risk of physical tampering and/or data theft.

System and Communications Protection

9. Monitor and control communications at system boundaries.

Network traffic needs to be inspected and controlled to catch threats early. 

Firewalls and intrusion detection tools are used to monitor traffic entering or leaving your network and block suspicious activity, and setting up logging and alerting for traffic anomalies cues you into threats early on.

10. Implement boundary protections such as firewalls and filters.

Network segmentation can both contain threats and reduce their impact. 

Actions such as applying email filters and web proxies, enforcing traffic rule zones between zones, and creating VLANs to isolate sensitive systems will limit the radius of a breach and keep attackers from causing further harm.

11. Use cryptographic methods when transmitting FCI.

Sensitive data in transit needs to be protected from being intercepted. The recommended controls around this are enforcing TLS for all network communications, using secure transfer protocols, and encryption.

Encryption For CMMC

Systems and Information Integrity

12. Identify system flaws (e.g., patches) and manage them.

Outdated systems are prime targets for attackers. This is why it is crucially important to keep systems up to date by applying security patches regularly.

For CMMC Level 1, organizations need to be accomplishing this by prioritizing critical updates, applying patches on a schedule with a documented process, and regularly checking for software updates.

13. Take steps to protect against malicious code, such as antivirus.

Malware can compromise systems and exfiltrate data. To combat this risk, deploying anti-malware tools to block viruses and other threats that could compromise FCI are industry standard steps.

14. Monitor system activity for security events.

Without visibility, threats can go undetected for months. It’s crucial to set up a way to track system logs in order to detect unusual behavior that could indicate a breach or misuse. To accomplish this, organizations often implement a SIEM platform, or other tools to monitor for suspicious behavior. 

15. Perform periodic system scans and take corrective action. 

Running regular vulnerability scans to detect weaknesses and applying fixes or updates as needed to keep systems secure is something every organization should be doing. The business value of this last control is keeping your security posture strong and supporting audit readiness.

CMMC Level 1 Checklist: Self-Attestation For CMMC Level 1

Unlike Level 2 and Level 3, Level 1 does not require a third-party assessment. 

Instead, your organization must annually self-attest to meet all 15 practices. That attestation must come from a senior company official and be submitted through the Supplier Performance Risk System (SPRS). 

Most organizations will need to document the following for Level 1:

Although Level 1 is a massive degree less resource-intensive than Level 2 or 3, that doesn’t mean that accountability is any less important! Contractors who don’t meet these requirements can face contract risks. 

Here is how long you can anticipate CMMC Level 1 to take:

CMMC Level 1 Timeline

Partner For Success: Work With An Accredited C3PAO

Meeting CMMC requirements is a complex process, even for Level 1. 

The good news is that you don’t have to do it alone. Our partnership with industry leader A-LIGN, an accredited C3PAO, gives you access to both the security legwork needed to meet requirements as well as certified assessment services. Working with trusted partners speeds up the timeline for CMMC.

Together, we help organizations prepare for CMMC with confidence. Whether you are just getting started or finalizing your readiness for an assessment, we’re here to support your compliance journey with security expertise and a trusted C3PAO partner. 

C3PAOs are the only organizations authorized by the CyberAB to perform official CMMC assessments, if you need to go beyond self-assessments. Their involvement is essentially a must-have for any contractor aiming for certification. Meanwhile, as a Registered Provider Organization (RPO), Rhymetec works hand-in-hand with A-LIGN to help you prepare for that assessment. 

RPOs are approved to offer consulting and readiness support, and help you implement required controls, remediate gaps, and make sure your security practices and documentation align with CMMC standards. 

Together with A-LIGN, we are proud to offer this streamlined option for our clients. Contact us today to get started.


The federal government spends more than $100 billion annually on IT services, much of it through contracts with private companies. That level of investment brings strict cybersecurity expectations, especially for contractors that handle government data. 

Two frameworks frequently encountered in this space are the Cybersecurity Maturity Model Certification (CMMC) and the Federal Risk and Authorization Management Program (FedRAMP). Both programs share the same goal of protecting sensitive information. However, they serve slightly different purposes and apply to different types of vendors. 

CMMC is designed for companies working with the Department of Defense, in particular for those that handle Controlled Unclassified Information (CUI). Over 100,000 companies are part of the Defense Industrial Base. Any of them that handle CUI will eventually need to meet CMMC Level 2 or 3. 

Meanwhile, FedRAMP applies to cloud service providers working with civilian federal agencies. If you are a defense contractor, a SaaS provider, or if your organization supports both civilian and DoD programs, it's important to understand how CMMC and FedRAMP compare.

This article outlines the main differences between CMMC and FedRAMP, including which types of organizations they apply to, the requirements of each framework, and how to handle certification.

CMMC vs. FedRAMP

Who Needs CMMC and Who Needs FedRAMP?

CMMC and FedRAMP apply to different groups of contractors and vendors based on two factors: 

  1. The agencies they serve, and
  2. The type of data they handle. 

In short, if you're in the DoD supply chain, you may need to meet CMMC. If you're a cloud provider for civilian agencies, you may need FedRAMP authorization. Some organizations may need to pursue both if they serve both sides of the government in these capacities.

Below is a non-exhaustive list of a few common types of companies to which CMMC would apply. Remember that CMMC applies to companies that do business with the Department of Defense (DoD) and process, store, or transmit Controlled Unclassified Information (CUI) or Federal Contract Information (FCI): 

Basically, if a company touches DoD contract information in any way (and in particular if it involves CUI), it will most likely fall under CMMC. 

FedRAMP, on the other hand, applies to cloud service providers that want to sell their platforms or applications to civilian federal agencies (non-DoD). The types of companies this would include are:

For more information on what you will need to plan for to meet CMMC requirements specifically - and depending on which level of CMMC you need - check out our CMMC Level 1 Checklist and our CMMC Level 2 Checklist.

Security Requirements Compared

While CMMC and FedRAMP indeed share some overlap given their common goal to protect sensitive government data, they are built on different baseline requirements, and their approaches to security controls differ.

CMMC is based on the NIST SP 800-171 framework. It requires organizations to implement 110 security controls across 14 control families if they handle CUI and need to meet Level 2 certification. For organizations handling only FCI (Federal Contract Information), Level 1 requires 15 controls focused on basic security hygiene. CMMC's overall requirements are structured around the following security considerations:

Additionally, organizations must also produce documentation, including System Security Plans (SSPs) and Plans of Action and Milestones (POA&Ms), and be ready for assessment by a third-party assessment organization (C3PAO) at Level 2 or 3. Lastly, it's important to note that CMMC 2.0 is not a point-in-time audit. Contractors are required to maintain compliance continuously. For Levels 2 and 3, assessment will lapse upon failure to annually affirm, according to the DoD's CMMC Guidance.

CMMC vs FedRAMP Assessments

FedRAMP, by contrast, is based largely on NIST SP 800-53 controls, which are a bit more complex in scope. A Moderate FedRAMP authorization requires over 300 controls across a wide range of domains, including:

FedRAMP places more emphasis on supply chain risk management, cloud architecture documentation, and the remediation of vulnerabilities. Cloud service providers must show that they have a set of documents to pass the Joint Authorization Board or agency review. 

Documentation and Assessment Differences To Be Aware Of: CMMC vs. FedRAMP

The goal of documentation for CMMC (at Level 2) is to show that your organization meets the 110 controls from NIST SP 800-171. This includes documentation of:

  1. How controls are being implemented, and the plan for how they will be maintained. This documentation is your System Security Plan (SSP).
  2. A Plan of Action and Milestones (POA&M) - A list of gaps and a plan for remediation, with specific steps. 
  3. A list of policies and procedures, showing how your organization covers access control, incident response, configuration management, and other security controls. 
  4. Evidence of implementation (such as user logs, training records, configuration screenshots, etc) also must be included in your documentation. 

Finally, assessment is conducted by a C3PAO (Certified Third-Party Assessment Organization) for Level 2. Self-assessment is allowed at Level 1 (and in some cases, for Level 2), but must still be documented in SPRS (Supplier Performance Risk System) and affirmed by a senior official. 

*It's important to note that if you need CMMC Level 3, you will still need C3PAO affirmation completed on an annual basis, according to the DoD's updated overview of CMMC. For CMMC Level 3, the ongoing C3PAO assessments are in addition to undergoing an assessment every 3 years by the Defense Contract Management Agency's Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). 

FedRAMP documentation, meanwhile, is part of a full authorization package submitted to either a sponsoring agency or the Joint Authorization Board. Required documents include: 

  1. System Security Plan (SSP) - this can often reach over 600 pages for Moderate-level systems!
  2. A Privacy Impact Assessment that identifies how personal data is being collected, used, and protected.
  3. A Continuous Monitoring Plan detailing how your organization will monitor system changes, incidents, and vulnerabilities.
  4. An Incident Response Plan, showing how incidents will be reported and handled.
  5. Documentation showing how system changes are approved and tracked (also known as a Configuration Management Plan). 

Assessment is carried out by a third-party assessment organization that has been recognized by the FedRAMP PMO (Program Management Office). FedRAMP requires ongoing authorization maintenance, which takes the form of monthly vulnerability scans, incident reporting, and annual reassessments. 

How Certification Works: CMMC vs. FedRAMP

CMMC 2.0 certification is tied to a company's eligibility for Department of Defense contracts. Depending on the sensitivity of the data involved, contractors must meet either Level 1 (self-assessed) Level 2 (typically third-party assessed) requirements, or Level 3 (third-party assessed). As discussed in greater detail in the previous sections, the process entails the following steps:

The first step is to conduct an internal NIST 800-171 gap assessment to compare where you are versus where you need to be. The next step is to document your System Security Plan and Plan of Action and Milestones, followed by finally engaging a certified third-party assessment organization (for Level 2 and 3). 

There is no central approval body, and certification is granted per contract, with the assessment scope being based on the environment that contains CUI. 

FedRAMP follows a centralized authorization process managed by the FedRAMP Program Management Office. There are two paths:

  1. Agency Authorization. For this option, a single agency sponsors the cloud service provider and reviews the authorization package. 
  2. Joint Authorization Board. Authorization via a Joint Authorization Board (which comprises the DHS, GSA, and the DoD) involves a higher bar of scrutiny. 

For the FedRAMP process, your organization will work with a Third-Party Assessment Organization to complete your Security Assessment Plan and Security Assessment Report. You'll then need to submit a full authorization package through FedRAMP's secure repository, and finally, undergo ongoing monitoring after approval.

Can You Be Compliant With Both?

The short answer is yes.

If your organization provides cloud-based services to civilian agencies and works with the Department of Defense, you likely need to comply with both FedRAMP and CMMC. For example, a SaaS company that supports DoD contracts involving CUI will need CMMC Level 2, and if the same product is then sold to a civilian agency (like the Department of Energy), they will also need FedRAMP authorization. 

CMMC and FedRAMP share foundational requirements from NIST standards. But it's not a direct map on - meeting FedRAMP Moderate, for instance, doesn't automatically mean you meet CMMC Level 2. The good news is it absolutely does reduce duplication in areas such as access control, system monitoring, and incident response. 

If you do need both CMMC and FedRAMP, figuring out early on how to align both compliance efforts can reduce cost and headaches down the road. This is a common use case for working with a consultant to manage both tracks. A consultant has the experience implementing these requirements across a large spectrum of different types of organizations, and can help ensure efficient implementation.

When To Bring In A Consultant Or MSSP

A recent report by the U.S. Government Accountability Office shows that many small businesses in the defense industry lack the internal resources to implement NIST 800-171 without outside help. This illustrates a growing need for CMMC consultants and MSSPs. 

In the report, many smaller businesses in particular expressed concerns about the costs and resources required for CMMC implementation. This is where outsourcing the process can be transformative. Outsourcing is a fraction of the investment that building out an in-house team to carry out the implementation process would be. 

The fact is that organizations often wait too long to bring in help, and this can lead to missed deadlines and unnecessary rework. If you're pursuing CMMC, FedRAMP, or both, bringing in a consultant early can reduce risk and cost. 

It can be a good idea to bring in a consultant or MSSP if you don't have internal staff with experience in NIST 800-171 or 800-53 implementation, if you're unsure how to scope your CUI, if you're being asked to respond to a security questionnaire and aren't confident in your answers, or if you need to align your environment for both frameworks. 

A consultant will perform a gap analysis, build a compliance roadmap, draft documentation for you, implement technical controls, and fully prepare your team for assessment. For small and mid-sized organizations, especially those with aggressive go-to-market timelines, outsourcing to a qualified team helps avoid delays and prevents compliance from blocking growth.

About Rhymetec

Our mission is to make cutting-edge cybersecurity available to SaaS companies and startups. We’ve worked with hundreds of companies to provide practical security solutions tailored to their needs, enabling them to be secure and compliant while balancing security with budget. We enable our clients to outsource the complexity of security and focus on what really matters – their business. Contact us today to get started.

With a Registered Practitioner on Staff and a Proven Track Record, the Company Solidifies Its Role as a Leading Partner for Defense Contractors Navigating New CMMC Requirements.

NEW YORK, May 28, 2025 – 

Rhymetec, the industry leader in cloud security that provides innovative cybersecurity, compliance, and data privacy services to modern-day SaaS businesses, today announces it has achieved the status of Cybersecurity Maturity Model Certification (CMMC) Registered Provider Organization (RPO) through CyberAB. Developed by the U.S. Department of Defense (DoD), the CMMC Program is a set of rules designed to strengthen cybersecurity and protect sensitive government information shared with defense contractors.

As a CMMC RPO, Rhymetec is equipped to provide expert advisory and compliance readiness and maintenance services to help organizations understand CMMC requirements, implement necessary controls, and prepare for audits and assessments. This milestone is especially timely, as the final CMMC requirements take effect this month, making compliance essential for contractors looking to win or retain DoD contracts. Rhymetec's commitment to advancing CMMC readiness is further demonstrated by its active participation in industry events such as CEIC West and recent collaborations with leading compliance partners like Vanta and A-LIGN.

"With the final CMMC requirements now in effect, defense contractors and subcontractors are under real pressure to get compliance right," said Justin Rende, founder and chief executive officer of Rhymetec. "Achieving RPO status reinforces our commitment to guiding clients through this critical process with clarity, confidence, and deep expertise."

In addition to being a designated CMMC Registered Provider Organization (RPO), Rhymetec's chief information security officer (CISO), Metin Kortak, has earned the credential of CMMC Registered Practitioner (RP). This distinction underscores the company's dedication to cybersecurity excellence and hands-on expertise. Having a certified RP on staff is not only a requirement for RPOs but also enhances the value of Rhymetec's advisory and managed services, enabling more strategic guidance and tailored preparation for organizations seeking certification under the latest CMMC standards.

"CMMC isn't just about checking boxes; it's about building a resilient security posture that can stand up to real-world threats," said Metin Kortak, CISO of Rhymetec. "As a Registered Practitioner, I'm proud to help organizations cut through the complexity and take actionable steps toward long-term compliance and protection."

If your organization needs guidance navigating the complexities of CMMC compliance, including conducting gap assessments or self-assessments, developing System Security Plans (SSPs), drafting a Plan of Action and Milestones (POA&M), implementing required security controls, and supporting remediation efforts, Rhymetec can help.

You can read the original press release on PR Newswire.

About Rhymetec

Rhymetec is an industry leader in cloud security, providing innovative cybersecurity and data privacy services to the modern-day SaaS business. The company builds, deploys and manages compliant information security and data privacy programs directly within their customers' unique environments, allowing them to focus on their core competencies within their business. Over the years, Rhymetec's services have grown to include a vCISO (Virtual CISO) program, ISO Internal Audits, and a variety of Penetration Testing services. For more information, please visit www.rhymetec.com and follow us on LinkedIn.

Deepak Chopra once said, "All great changes are preceded by chaos." This has never been more accurate than when it’s applied to the current AI and cybersecurity environments—and the regulations that govern them.

New frameworks like the Digital Operational Resilience Act (DORA), the EU AI Act, the Network and Information Systems Directive 2 (NIS2) and the Cybersecurity Maturity Model Certification (CMMC) are reshaping how businesses handle security, risk and compliance. These regulations aren't just about ticking boxes—they carry major financial penalties and demand real operational changes.

For companies in financial services, AI development, critical infrastructure or defense, staying ahead of the changes is vital to avoid penalties, protect data and maintain trust. Let's look at what each entails.

DORA: Protecting Financial Institutions From Cyber Disruptions

Financial institutions face constant cyber threats and operational risks. DORA aims to empower financial organizations to weather system disruptions and continue operating smoothly.

DORA requires penetration testing, vulnerability assessments and disaster recovery planning. It focuses on business continuity to ensure that if a system fails, a plan is in place to keep operations running. Banks, insurance companies and investment firms must validate security controls through rigorous testing.

This regulation is a wake-up call for financial institutions to take cybersecurity resilience seriously. The penalties for non-compliance are severe, making it crucial for businesses to invest in robust security testing and operational risk management.

The EU AI Act: Setting The Global Standard For AI Compliance

AI development currently operates in a regulatory gray area, but the EU AI Act is changing that. One of the first laws to set clear boundaries on AI usage, it focuses on ethical risks, security concerns and prohibited applications.

The most important takeaway is the significant financial penalties for non-compliance: These can be up to 7% of a company's global annual revenue or 35 million euros, whichever is higher. That's more than GDPR, which has already forced businesses worldwide to rethink their approach to data privacy.

This law explicitly bans certain AI applications, particularly those that exploit vulnerabilities. The ban includes AI-powered cyberattacks, social manipulation and unethical facial recognition practices. Article 5 of the act outlines prohibited AI uses, such as systems that exploit people's age, disabilities or socioeconomic circumstances.

This isn't simply a privacy factor; its purpose is to prevent AI from being weaponized.

A common misconception is that this law only affects European companies. That's not the case. Any company developing, deploying or processing AI systems in the EU—or serving EU customers—must comply. For example, if a U.S. company hosts its platform in an EU data center or processes European customer data, this regulation applies.

The EU AI Act is setting the stage for global AI governance. Similar regulations are expected to emerge worldwide, making it smart for businesses to adapt now rather than scrambling to comply later.

NIS2: Strengthening Cybersecurity For Critical Infrastructure

Also in the EU, the NIS2 Directive expands cybersecurity requirements for critical industries like energy, healthcare, transportation and digital services. It builds on the original NIS Directive but goes much further, applying to more organizations, increasing security expectations and enforcing stricter penalties.

The enhanced reporting requirements are one of the biggest challenges. Companies must notify regulators of cyber incidents within 24 hours, provide a complete assessment within 72 hours and demonstrate they are actively managing security risks.

The directive also emphasizes stronger supply chain security, holding companies responsible for ensuring their vendors meet cybersecurity standards. This means businesses can't just secure their own systems—they must also vet suppliers and partners to prevent weak links in the supply chain.

Beyond reporting and supply chain oversight, NIS2 enforces stricter governance requirements. Organizations must appoint security officers, conduct regular risk assessments and develop robust cybersecurity policies. Those that fail to comply face heavy financial penalties and increased regulatory scrutiny.

Compliance isn't optional for companies operating in or serving the EU market. NIS2 is setting a new cybersecurity standard, and businesses that don't act risk fines, operational disruptions and reputational damage.

CMMC: Raising the Bar For U.S. Defense Contractors

The CMMC is a requirement for companies working with the U.S. Department of Defense (DoD). It builds on cybersecurity frameworks like NIST 800-171, ensuring that defense contractors follow strict security protocols to protect sensitive government data.

Recent changes to CMMC include a new self-assessment option for Level 1 compliance, making it easier for smaller contractors to meet requirements without hiring third-party auditors. However, higher certification levels still require independent verification, adding layers of accountability.

With the new compliance requirements going into effect in mid-2025, businesses need to act now. The DoD has made it clear that CMMC certification will be mandatory for contracts, and companies that don't comply risk losing business.

Evolving Security Frameworks: A Smarter Approach To Compliance

For organizations handling sensitive data in healthcare, finance and other regulated industries, new security frameworks present a way to prove compliance with strict privacy and cybersecurity standards. In the past, certification required a lengthy, one-size-fits-all assessment, but newer models offer more flexible options with fewer controls, reducing complexity while maintaining security.

Many businesses don't realize that certification levels vary, and choosing a lower-tier option may not meet regulatory or customer expectations. This is especially important for HIPAA compliance, where recognized certifications can demonstrate that companies meet security standards. As cybersecurity laws evolve, understanding these frameworks ensures that businesses stay compliant, competitive and prepared for future regulations.

Laws like DORA, the EU AI Act and NIS2 are designed to keep technology from becoming a threat. AI development currently lacks clear rules—without oversight, it can be used in dangerous ways. These regulations force businesses to prioritize security and ethics upfront, preventing bigger problems down the road.

To stay ahead, organizations must:

  1. Identify relevant regulations and update security policies.
  2. Invest in risk assessments, penetration testing and employee training.
  3. Stay informed—more regulations are coming.

Compliance isn't just about avoiding penalties but about building a safer, more resilient digital future. Companies that act now will lead, while those that wait will fall behind.

You can read the original article posted in Forbes by Rhymetec CISO, Metin Kortak.

About Rhymetec

Our mission is to make cutting-edge cybersecurity available to SaaS companies and startups. We've worked with hundreds of companies to provide practical security solutions tailored to their needs, enabling them to be secure and compliant while balancing security with budget. We enable our clients to outsource the complexity of security and focus on what really matters – their business. Contact us today to get started.

Working with a CMMC consultant is an attractive option for many organizations seeking to meet the updated CMMC requirements nowadays.

The Department of Defense (DoD) released CMMC 2.0 on October 15th, 2024, a requirement for defense contractors and subcontractors with the goal of improving cybersecurity standards. The updated version refines the original framework, aiming to simplify the path to compliance while maintaining the highest security standards for organizations that handle Controlled Unclassified Information (CUI) and other sensitive contract data. 

One way in which the updated version simplifies compliance is by aligning requirements even more closely with existing cybersecurity standards like NIST SP 800—171. Many organizations may already comply with NIST 800-171 or another framework very closely aligned with it. Either way, the shift in compliance expectations has led many organizations to assess whether they have the in-house resources to manage security or if they need external support through a CMMC consultant.

CMMC Consultant vs. In-House Compliance Options

Working with a Managed Security Services Provider that offers CMMC consulting services (like Rhymetec!) can help contractors meet CMMC 2.0 requirements efficiently. MSSPs take the work off your plate and help you meet your goals in the fastest time frame possible. We've helped over 1,000 organizations meet their compliance and security requirements in the fastest time frame possible.

In this article, we go over how CMMC 2.0 works, the options available for achieving compliance, and the potential advantages of working with a CMMC consultant.

What Is A CMMC Consultant, and What Do They Do?

Unless you have a fully built-out in-house cybersecurity and compliance team, CMMC can be a massive project to take on internally—taking a year or longer to meet requirements. This is where a CMMC consultant comes in.

A CMMC consultant is a cybersecurity and compliance expert who helps defense contractors meet the requirements of the Cybersecurity Maturity Model Certification (CMMC) 2.0. Consultants do everything from conducting a gap assessment to see where you are versus where you need to be, developing practical strategies to achieve compliance that will fit seamlessly (and as non-disruptively as possible!) into your operations, and guiding you through the certification process in partnership with an external auditor.  

For many businesses, especially small and mid-sized contractors, understanding and implementing CMMC controls can be challenging. A CMMC consultant provides tailored, specialized knowledge to streamline the entire process, reduce your risk of non-compliance, and make big improvements to your overall security if you do not already have certain measures in place.

Do You Need A CMMC Consultant?

The best way to determine if you need a CMMC consultant is to look through the responsibilities and deliverables in the next section and assess whether or not you have the in-house capacity to fulfill all of these items. 

If you are a larger organization and already have a security team with personnel that can accomplish the necessary tasks for CMMC (A Chief Information Security Officer, Penetration Tester, Cloud Security Specialist, Vulnerability Management Analyst, etc.), you can probably do most of this on your own or with guidance from a CMMC consultant rather than full support. 

However, for smaller organizations or those without a fully developed in-house security program, engaging a CMMC consultant entails multiple benefits. 

According to A-LIGN’s 2025 Compliance Benchmark Report, 57% of government-affiliated organizations reported conducting audits specifically to meet contract requirements, up from 40% in 2024. DoD contractors and subcontractors will need to obtain certification under one of three trust levels to demonstrate that they have adequately implemented cybersecurity measures.  

Below are some questions to help you assess whether working with a consultant is the right choice. After you answer these questions and review the responsibilities and deliverables listed below in the next section, you should have a clear picture of whether or not you need a CMMC consultant:

1. Which CMMC Level Do You Need To Achieve?

The CMMC level you need depends on the type of contracts you handle:

CMMC Level 1 (Basic Cyber Hygiene) is required for contractors who only handle Federal Contract Information (FCI). Compliance is self-assessed, but security controls must still be implemented.

CMMC Level 2 (Advanced Cyber Hygiene) is required for contractors who handle Controlled Unclassified Information (CUI). Compliance requires a third-party assessment (C3PAO) every year.

CMMC Level 3 (Expert) is required for contractors who are working on high-security DoD projects. Compliance entails DoD-led audits and adherence to NIST SP 800-171 and portions of NIST SP 800-172.

If you need CMMC Level 2 or Level 3, working with a CMMC consultant can be extremely helpful, given the amount of work involved in the third-party assessment process, implementing missing security controls, and maintaining ongoing compliance. 

2. Do You Have An Internal Cybersecurity Team With Compliance Expertise?

If you have a dedicated cybersecurity and compliance team, you may be able to handle CMMC requirements internally. Even if you do have an internal team, however, a CMMC consultant can still be beneficial if:

3. Have You Implemented a NIST 800-171 Self-Assessment?

If you need CMMC Level 2 or Level 3, you should already have a NIST 800-171 self-assessment and an SPRS score recorded. If you haven't completed this step, a CMMC consultant can guide you through the process. Additionally, if your SPRS score is low, or if you have many missing security controls, you may need a consultant to develop a remediation strategy before moving forward. 

4. Do You Need Help Implementing Technical Security Controls?

There are a range of technical security controls required by CMMC that many organizations may not have adopted yet. If your company lacks the bandwidth to deploy these measures, a CMMC consultant can provide guidance and support (or do it for you, depending on the level of support outlined in the engagement). These types of technical controls include configuring multi-factor authentication, implementing network segmentation, SIEM logging and monitoring, and vulnerability management. 

5. Are You Prepared For A Third-Party or DoD Audit?

For Levels 2 and 3, organizations have to pass an official assessment conducted by a Certified Third-Party Assessor Organization (C3PAO) or the DoD. The most common issues contractors face with these assessments are due to insufficient documentation, improperly implemented controls, or lack of audit preparation. A CMMC consultant can remediate these issues and more in advance of your assessment. 

6. Do You Need Ongoing Compliance Support?

Lastly, it's important to know that CMMC compliance requires ongoing monitoring and maintenance. You'll need to keep your certification in good standing year-round. If your organization does not have a dedicated team to handle continuous compliance, a CMMC consultant can provide long-term security and compliance management. Ongoing support can include:

If the answer is "yes" to multiple questions, partnering with a CMMC consultant may be a good option for your organization. 

Do You Need A CMMC Consultant?

Next, let's go over what a CMMC consultant typically accomplishes for organizations throughout the engagement. This should help give you a good idea of what to expect:

Timelines And Deliverables From A CMMC Consultanting Engagement  

A CMMC consultant provides end-to-end support to help defense contractors achieve CMMC compliance. At a high level, this process entails assessing your organization's current security posture, implementing the required controls you don't already have, developing documentation, training personnel, and preparing for the official assessment. 

Here is what this process and the deliverables will look like, in general, for an organization starting from a more basic security posture:

1. CMMC Initial Assessment - Documentation and Gap Assessment: 

Timeline With A CMMC Consultant: 1-2 Months 

2. Implementation of Access Control and System Security

Timeline With A CMMC Consultant: 1-3 Months 

3. Documentation and Policy Development

Timeline With A CMMC Consultant: 1-2 Months 

4. Training

Timeline With A CMMC Consultant:  1 Month 

5. Testing and Control Validation

Timeline With A CMMC Consultant: 1-2 Months 

6. C3PAO Assessment

Timeline With A CMMC Consultant: 1 Month 

Ongoing Maintenance

To maintain compliance and readiness for recertification, a CMMC consultant provides ongoing support through the following:

CMMC Consultant Deliverables and Timelines

Why Work With A CMMC Consultant?

Achieving compliance is not simple. There is an array of technical and procedural controls and extensive required documentation. A CMMC consultant helps businesses navigate these requirements by providing specialized expertise (at a much lower price point than building out an in-house team would cost) and reducing administrative burdens. 

Many defense contractors lack the in-house resources to manage requirements, especially as the DoD increases enforcement of cybersecurity standards. Often, for example, small defense contractors with no formal cybersecurity programs need to achieve CMMC Level 1 to continue bidding on DoD contracts. Having limited IT staff and a lack of security policies and policies can be a significant roadblock.

In this scenario, a CMMC consultant would help by starting with an initial assessment to determine the company's current security posture and documentation and, from there, develop all missing policies, procedures, and documents. Often, this includes a System Security Plan (SSP), access control policies, and an incident response plan. 

Many contractors also underestimate the complexity of CMMC and wait too long to start the process. The risk of failing an assessment can lead to contract loss and reputational damage. Working with a CMMC consultant reduces risk, streamlines implementation, strengthens your cybersecurity, and ensures you stay audit-ready year-round.

If your business relies on DoD contracts, CMMC certification isn't optional. Engaging a CMMC consultant early on in the process saves significant time and headaches down the road. 

About Rhymetec

Our mission is to make cutting-edge cybersecurity available to SaaS companies and startups. We’ve worked with hundreds of companies to provide practical security solutions tailored to their needs, enabling them to be secure and compliant while balancing security with budget. We enable our clients to outsource the complexity of security and focus on what really matters – their business. Contact us today to get started.

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