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

As of December 2024, CMMC is Enforced – Is Your Business Ready?  

The Cybersecurity Maturity Model Certification (CMMC) is now a requirement for organizations working with the Department of Defense (DoD). If your company stores, processes, or transmits Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), compliance is now mandatory to continue bidding on and fulfilling DoD contracts.  

 Many businesses are now asking:  

• Do we need CMMC certification? 
• What level of compliance do we need?  
• How do we achieve and maintain compliance?  

Below is a breakdown of what you need to know and how to ensure your organization meets these requirements.  

CMMC is the DoD’s cybersecurity framework designed to protect sensitive government information across the defense supply chain. It is based on the security controls outlined in NIST SP 800-171 and introduces third-party assessments to validate compliance.  

CMMC 2.0: The Latest Version

CMMC 2.0, introduced in November 2021, streamlined the original model to focus on three maturity levels:  

• Level 1: Foundational (Self-assessed) – Basic cyber hygiene for companies handling FCI. 
  
• Level 2: Advanced (Third-party-assessed) – Aligns with NIST SP 800-171, required for handling CUI. 
  
• Level 3: Expert (Government-assessed) – Designed for high-priority contractors dealing with critical national security information.  

If your organization handles CUI, Level 2 is the minimum requirement to continue working with the DoD.  

1. Enforcement Has Started—Non-Compliance Means Lost Contracts  

As of December 2024, CMMC compliance is contractually required. Companies failing to meet the necessary certification level will lose eligibility to bid on new DoD contracts or renew existing ones.  

 2. Cyber Threats Are Increasing in the Defense Supply Chain  

The Defense Industrial Base (DIB) is a prime target for cyberattacks. Data breaches, ransomware, and nation-state threats pose a significant risk. CMMC ensures that organizations implement strong security controls to protect sensitive information.  

 3. Compliance Is Not Just for Large Contractors  

CMMC applies across the entire defense supply chain, including:  

• Prime contractors  
• Subcontractors  
• Suppliers and vendors  
• Manufacturers handling sensitive defense data  

Even if your company is not a direct DoD contractor, you may still be required to comply if your partners or customers require CMMC certification for contract eligibility.  

1. Determine Your Required CMMC Level  

• If you handle CUI, you must be at Level 2 or higher.  
  
• If you only handle FCI, Level 1 may be sufficient, but self-assessments are required. 
  
• If you support national security-critical programs, Level 3 applies and requires a government-led assessment.  

2. Conduct a Gap Assessment  

A CMMC gap assessment identifies where your organization is non-compliant and what needs improvement. Areas to evaluate include:  

•  Data discovery and classification to identify where FCI and CUI reside in your systems. 
  
• Access control policies to limit access to sensitive data based on user roles. 
  
• Incident response and logging to establish protocols for detecting and responding to security threats.  

3. Implement and Maintain Compliance Controls  

Achieving CMMC certification requires more than just an assessment—it requires continuous security practices that align with NIST SP 800-171 controls. Key areas include:  

• Encrypting sensitive data at rest and in transit. 
  
• Using multi-factor authentication (MFA) to protect access. 
  
• Regularly auditing and monitoring access to CUI. 
  
• Training employees on cybersecurity best practices.  

4. Partner with Experts to Simplify Compliance  

Many organizations struggle with the complexity of compliance, especially tracking unstructured data that falls outside traditional security protections. This is where Spirion can help.  

1. Discover and Classify CUI Across Your Organization  

Many businesses do not know where CUI is stored, and you cannot protect what you cannot find. Spirion provides:  

• Automated discovery of sensitive data across files, emails, and cloud storage. 
  
• Custom identifiers to label and classify CUI based on DoD requirements. 
  
• Continuous data monitoring to track risks and exposure.  

2. Strengthen Your Compliance Readiness  

Spirion helps organizations align with CMMC and NIST 800-171 controls, ensuring that security policies are effectively implemented. Key benefits include:  

• Risk assessment and compliance reporting to identify security gaps.
  
• Role-based access control and data protection to enforce security policies.
  
• Audit-ready documentation for CMMC self-assessments and third-party assessments.  

3. Reduce Complexity and Stay Ahead of Future Requirements  

CMMC will continue to evolve. Spirion’s subject matter experts keep you updated and help simplify the compliance process so you can focus on your business.  

CMMC compliance is no longer optional—it is a requirement that determines your eligibility for DoD contracts. If you have not started preparing, now is the time.  

 Next Steps:  

1. Identify your required CMMC level. 

2. Assess your compliance gaps.  

3. Implement controls to secure CUI and FCI . 

4. Engage with experts to streamline your journey.  

If your organization touches DoD information in any capacity, you need to act now. Spirion has helped other businesses navigate this transition—let’s talk about how we can help you.