6 Months of CMMC Lessons: Why CMMC Level 2 Takes 9–12 Months, Not 90 Days.
- Socium Security
- Jul 7
- 4 min read
Organizations pursuing Cybersecurity Maturity Model Certification (CMMC) 2.0 Level 2 compliance have been encountering several recurring challenges. These obstacles are particularly pronounced for small to mid-sized businesses within the Defense Industrial Base (DIB), especially those serving Fortune 250 clients. Socium has prepared organizations with their CMMC Level 2 preparedness and audit plans. These are the primary roadblocks we have seen in the last six months:
1. Misaligned Timelines and Unrealistic Expectations
Connecting the back office operations to the front office customer facing teams and communicating expectation effectively with executives has become an art and challenge to manage. Each team desires the same outcome but with various understanding of organizational constraints.
Many organizations underestimate the time and resources required to achieve Level 2 compliance. While some advisors suggest a 90-day timeline, the process often spans 9–12 months. This duration accounts for comprehensive gap analyses, remediation efforts, and preparation for third-party assessments.
2. Challenges in Scoping and Identifying Controlled Unclassified Information (CUI)
Sales and Executives want their CMMC certification. Security wants to know what to secure. Product and operations are somewhere in the middle. In most cases, revenue leads the way but what is driving revenue (systems, data, users, etc.) still needs to be clearly defined.
Accurately determining the scope of systems and assets that process, store, or transmit CUI is a significant hurdle. Misidentification can lead to incomplete security implementations and audit failures. Proper scoping requires a thorough understanding of data flows and system boundaries.
And what if we created a fresh new environment to handle this data; can we make this easier? (Pst, the answer is “yes; well, it depends”).
3. Inadequate Documentation and Evidence Management
Compliance is not solely about implementing security controls; it also involves maintaining detailed documentation. Do what you say, say what you do – practice it. Organizations often struggle with creating and managing artifacts such as policies, procedures, and audit logs that align with their actual practices. Discrepancies between documented policies and operational realities can result in non-compliance. Keep it simple.
4. Resource Constraints in Small and Mid-Sized Businesses
Smaller organizations frequently lack the personnel and technical expertise to understand and interpret, let alone meet, the 110 security requirements outlined in NIST SP 800-171. This scarcity of resources hampers the implementation of necessary controls and the preparation for assessments. The fact is most organizations struggle to get it right the first time around, the path is rarely linear. Find your trusted partner who can create a more direct path from start to finish.
5. Complexities in Preparing for Third-Party Assessments
Transitioning from self-assessments to third-party evaluations introduces new complexities. Organizations must prepare for rigorous assessments that include documentation reviews, technical testing, and personnel interviews. Ensuring readiness across these areas is a common challenge because it feels uncomfortable, there is little to no de-scoping controls. Time and operational budget are lost if it is not done right the first time.
6. Confusion Due to Evolving Requirements
The shift from CMMC 1.0 to 2.0 has led to confusion, particularly regarding the alignment with NIST SP 800-171 and the introduction of new scoping definitions. Organizations must stay informed about these changes to ensure compliance.
7. Limited Availability of Certified Third-Party Assessment Organizations (C3PAOs)
The demand for C3PAOs exceeds the current supply, leading to scheduling delays and bottlenecks in the certification process. This scarcity can impede timely compliance for organizations ready for assessment. And oftentimes, the third-party Registered Practitioner Organizations are not experienced in the full lifecycle of the audit scoping, preparation, and audit management. Finding a trusted third party is difficult; finding one that adds value is even more challenging.
8. Integration of External Service Providers
Many organizations rely on external service providers, such as Managed Service Providers (MSPs) and Cloud Service Providers (CSPs). Ensuring these partners meet CMMC requirements and effectively integrate their services into the organization’s compliance framework is a complex task. With the global integration of systems, cloud, SaaS, and their support teams, it is painfully difficult to find clear guidance on the treatment and scoping of service providers.
9. Financial Constraints
Achieving CMMC Level 2 compliance involves significant financial investment. Costs associated with implementing controls, hiring consultants, and undergoing assessments can be burdensome, particularly for smaller businesses.
10. Continuous Compliance and Maintenance
Compliance is not a one-time effort, you’re in this cycle in perpetuity. Organizations must establish processes for continuous monitoring, regular updates, and periodic reassessments to maintain their certification status over time. There are costs due to added operational time, people, tools, licensing, etc.
Addressing these challenges requires a strategic approach, including early planning, resource allocation, and engagement with experienced compliance professionals. By proactively tackling these roadblocks, organizations can enhance their cybersecurity posture and achieve CMMC Level 2 compliance.
Where do you go from here?
Socium Security does not have all of the answers but we have prepared multiple organizations for audit with some of the most recognized audit firms in the country, if not the world. We are here to guide and give you the recipe for success as a partner in strategy, implementation, and the ongoing operation of your cybersecurity compliance program.
We offer Chief Compliance Officer as a service, fractional CISO services, and cybersecurity products to consolidate and streamline your increasing cybersecurity challenges.
