CMMC Level 2 Compliance: What They Don't Tell You
The Reality Check
If you’re working in the Defense Industrial Base, you’ve heard about CMMC (Cybersecurity Maturity Model Certification). Level 2 is the baseline for most contractors. The documentation makes it sound straightforward. It’s not.
What the Framework Covers
CMMC Level 2 aligns with NIST 800-171 - 110 security requirements across 14 domains. Sounds manageable until you realize each requirement can spawn dozens of implementation tasks.
The big categories:
- Access Control
- Audit and Accountability
- Configuration Management
- Identification and Authentication
- Incident Response
- Maintenance
- Media Protection
- Personnel Security
- Physical Protection
- Risk Assessment
- Security Assessment
- System and Communications Protection
- System and Information Integrity
The Hidden Challenges
Legacy Systems Are Your Enemy
You know that critical application running on Windows Server 2012? The one nobody wants to touch because it “just works”? Yeah, that’s now a compliance nightmare. Patching requirements don’t care about your technical debt.
Documentation Is Half the Battle
Having MFA? Great. Can you prove it’s configured correctly? Do you have evidence of how you handle MFA bypass requests? Is your incident response plan tested and documented?
The auditors want artifacts. Lots of artifacts.
User Pushback Is Real
Requiring CAC cards for physical access? Implementing stricter password policies? Blocking USB drives? Prepare for resistance. Executive leadership included.
What Actually Worked
Start with the POA&M (Plan of Action & Milestones). You won’t be 100% compliant immediately. Document your gaps, create realistic timelines, and show continuous improvement.
Automate evidence collection. Manual documentation doesn’t scale. Use your RMM, SIEM, and endpoint tools to automatically capture compliance evidence.
Get leadership buy-in early. CMMC compliance impacts everyone. If leadership doesn’t understand why they can’t use their personal Dropbox anymore, you’re fighting an uphill battle.
Invest in training. Your users are your weakest link and your strongest defense. Security awareness training isn’t optional anymore.
The Cost Nobody Talks About
Budget for:
- Consultant/assessor fees: $50-150K+
- New tools and licenses: $30-100K+
- Staff time (the hidden cost): Thousands of hours
- Ongoing maintenance: It never ends
Final Thoughts
CMMC isn’t impossible, but it’s not trivial either. Start early, document everything, and don’t try to do it alone. Find a good C3PAO (assessor) who actually understands your business.
And remember: perfect is the enemy of done. You need to be compliant enough to pass assessment and secure enough to actually protect CUI. Sometimes those aren’t the same thing.