CMMC Compliance: What You Need to Know Now That Enforcement Has Begun

The Cybersecurity Maturity Model Certification (CMMC) is no longer a looming deadline—it’s here. As of December 2024, organizations working with the Department of Defense (DoD) must comply to bid on or fulfill contracts involving Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). If your business isn’t certified, you’re already behind the curve—and the stakes couldn’t be higher. 

Businesses across the defense supply chain are scrambling to answer: 

• Do we need CMMC certification? 
• What level of compliance applies to us? 
• How do we get—and stay—compliant? 

Here’s your no-nonsense guide to navigating CMMC enforcement and securing your place in the DoD ecosystem. 

CMMC is the DoD’s rigorous cybersecurity framework, built to safeguard sensitive government data throughout its sprawling supply chain. Rooted in NIST SP 800-171 security controls, it mandates third-party assessments (for higher levels) to ensure your defenses hold up. This isn’t optional—it’s the new price of entry for DoD business. 

Launched in November 2021, CMMC 2.0 streamlined the original five-level model into three sharper tiers: 

• Level 1: Foundational (Self-Assessed) – Basic cyber hygiene for companies handling FCI. Think of it as the bare minimum. 
• Level 2: Advanced (Third-Party Assessed) – Matches NIST SP 800-171’s 110 controls, mandatory for CUI handlers. This is the sweet spot for most contractors. 
• Level 3: Expert (Government-Assessed) – Reserved for high-stakes players protecting critical national security data. 

If you handle CUI, Level 2 is indeed your minimum threshold for DoD contracts, aligning with NIST SP 800-171 requirements. Level 3 is rarer and government-driven. 

1. Enforcement Is Live—Non-Compliance = No Contracts 
   The CMMC final rule hit in December 2024, with a three-year phased rollout. But don’t sleep on this: uncertified companies are already losing eligibility. The DoD isn’t bluffing—compliance is your ticket to play. 

2. POA&Ms Offer Breathing Room—With Limits 
   CMMC 2.0 allows Plans of Action and Milestones (POA&Ms) for some gaps, giving you 180 days to fix them post-assessment. But high-priority controls (e.g., multi-factor authentication) must be locked down upfront. No shortcuts here. 

3. Assessment Bottlenecks Are Looming 
   With ~76,000 contractors needing certification and only 54 Certified Third-Party Assessor Organizations (C3PAOs) as of early 2025, the math doesn’t add up. Delays are inevitable—get in line now or risk being sidelined. 

4. Cyber Threats Are on the Rise in the Defense Supply Chain 
   The defense supply chain’s complexity creates a vast attack surface. Cybercriminals and nation-states exploit this through supply chain infiltration, targeting software and physical infrastructure. The DoD’s push for CMMC compliance reflects this urgency. Early 2025 data suggests threats are not just increasing in frequency but in sophistication—AI-powered attacks, physical-digital hybrids, and geopolitical motives are converging to make the DIB a bullseye. CMMC isn’t busywork—it’s a shield against real, escalating dangers. 

5. No One Escapes the Net 
   CMMC spans the entire DoD supply chain: prime contractors, subcontractors, vendors, manufacturers—everyone touching FCI or CUI. Even indirect players may need certification if their partners demand it. 

1. Pinpoint Your CMMC Level  
   • CUI in your systems? Level 2 or bust.
   • Only FCI? Level 1 might suffice, but self-assessment is still required. 
   • Critical national security data? Level 3’s government scrutiny awaits. 

2. Run a Gap Assessment 
   Audit your setup to spot weaknesses. Focus on:
   • Data Discovery: Where does FCI/CUI live in your network?
   • Access Controls: Who can touch sensitive data—and why?
   • Incident Response: Can you detect, log, and neutralize threats fast? 

3. Build Your System Security Plan (SSP) and POA&Ms 
   Document your cybersecurity posture and map out fixes for any gaps. This isn’t just paperwork—it’s your compliance lifeline. 

4. Lock Down NIST 800-171 Controls 
   Key moves:  
   • Encrypt CUI at rest and in transit. 
   • Deploy multi-factor authentication (MFA) everywhere. 
   • Audit access logs relentlessly. 
   • Train your team to spot phishing and fight back. 

5. Secure a C3PAO ASAP 
   Assessors are scarce. Booking one early could mean the difference between certification and a missed contract. 

• Discover and Classify CUI Like a Pro 
  You cannot protect what you cannot find. Spirion’s tools: 
  • Automatically discover sensitive data across files, emails, and clouds.
  • Tag CUI with DoD-compliant labels. 
  • Monitor sensitive data risk and exposure.  

• Fortify Your Compliance with Precision 
  Spirion delivers unmatched precision to conquer CMMC and NIST 800-171 demands. Here’s how it transforms your compliance game: 
  • Unrivaled Accuracy: Third-party tested at 98.5% accuracy, Spirion’s context- and content-aware approach ensures sensitive data discovery you can trust—no guesswork, just results. 
  • Comprehensive Reach: From structured databases to unstructured files and semi-structured logs, Spirion discovers data across on-prem systems, cloud environments, and endpoints. 
  • Context-rich Classifications: Persistent, interoperable, and contextual labels automatically signal downstream controls with the regulatory requirements, sensitivity, and purpose of your data—compliance made seamless. 
  • Native Remediation Power: Take decisive action with built-in tools—quarantine risky files, shred sensitive data, redact critical content, restrict access by reverting to default account objects, or execute custom scripts (batch or PowerShell) using third-party CLI capabilities. 
  • Audit-Ready Proof: Generate risk and exposure reporting for self-assessments or for third-party assessors. 

• Stay Ahead of the Curve 
  CMMC will continue to evolve—Spirion’s subject matter experts keep you in the know, cutting through complexity so you can focus on winning contracts. 

CMMC isn’t a suggestion—it’s your make-or-break moment. Non-compliance means no DoD dollars, period. If you haven’t started, you’re late—but not out. 

Next Steps: 

• Identify your CMMC level. 
• Assess your gaps. 
• Secure your data. 
• Partner with pros to fast-track the process. 

Need Clarity on Your Requirements?

Spirion’s CMMC specialists are ready to guide you. Contact Us. 
If you handle DoD data, the clock’s ticking. We’ve helped businesses conquer this—let’s get you across the finish line.