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Compliance · Defense Contractors

Understanding CMMC — What It Means for Your Business

If your company does any work for the Department of Defense, a cybersecurity requirement called CMMC now affects your ability to win and keep that work. Soon you won't just promise you're secure — you'll have to prove it through an independent assessment before the contract is awarded.

Why This Matters

Proving You're Secure — Not Just Promising It

CMMC — the Cybersecurity Maturity Model Certification — is the DoD's way of confirming that the companies it works with actually protect sensitive government information. The rule is now in effect and phases in over time. For many contracts, an independent certification will be required before you can be awarded the work.

Circle November 10, 2026

That's the point at which most contracts involving controlled information will require third-party certification before award. Because earning that certification commonly takes 12 to 18 months, the time to start is now.

What's Happening

The Timeline, in Plain Terms

The rule is live and rolling out in phases. Here are the dates that matter most.

Nov 10, 2025

The rule took effect

The DFARS acquisition rule is now live, phasing in over three years. Contracts that involve CUI began requiring a Level 2 self-assessment.

Nov 10, 2026

Third-party certification kicks in

The date to circle. Most contracts involving controlled information will require an independent, accredited assessment before the work can be awarded.

12–18 months

Typical time to certify

Earning certification commonly takes a year or more — assessment, documentation, and remediation all take time. The time to start is now, not next year.

The Three Levels

Which One Applies to You?

It usually comes down to one question: do you handle Controlled Unclassified Information?

Level 1

You handle basic Federal Contract Information (FCI).

How you prove it

You assess yourself once a year.

Level 2

Most common

You handle Controlled Unclassified Information (CUI). Most contractors are here.

How you prove it

An independent, accredited assessor (a C3PAO) certifies you.

Level 3

You handle the most sensitive information and face advanced threats.

How you prove it

The government assesses you directly (DIBCAC).

Not sure which applies to you? That's exactly the kind of question we help answer. Ask our team.

Your Next Steps

What You Should Do Now

Five practical moves, in order. The earlier you start, the smoother — and cheaper — this gets.

1

Find out if you're affected

Check your DoD contracts and ask your prime contractors whether CMMC requirements are coming. If you handle CUI, assume Level 2.

2

Get a gap assessment

Before you can certify, you need to know where you stand against the 110 security controls Level 2 requires. This is the single most useful first step.

3

Build your plan and paperwork

Certification requires a documented security plan (an SSP) and a remediation plan (a POA&M) for anything not yet in place.

4

Start early — assessor capacity is limited

There are only so many accredited assessors, and the line is growing. Companies that wait face higher costs and a real risk of missing contract deadlines.

5

Confirm your IT can handle CUI

Standard commercial email and tools often aren't enough for CUI — you may need a specialized, government-grade environment. We can advise on this.

Buyer Beware

What to Watch Out For

A few red flags that separate a legitimate CMMC partner from a shortcut that will cost you later.

One vendor can't both fix and certify you

If a vendor offers to remediate your gaps and certify you, walk away. That's a conflict of interest the rules prohibit — readiness help and the certification assessment must come from separate organizations.

SOC 2 is not the same as CMMC

If someone claims your existing certifications (like SOC 2) automatically make you CMMC-ready, be skeptical. They help, but they are not the same thing.

There's no certify-in-a-week

If you're told you can get certified in a few weeks, be cautious. Done properly, this is a months-long effort.

How KeyStone Helps

Get Ready, and Stay Ready

We assess where you stand today, build the security plan and documentation the assessment requires, put the right protections in place, and manage them over time so you stay compliant after you're certified. Wherever your sensitive data needs a more secure home, we'll help you design and run it.

  • Gap assessment against the 110 Level 2 controls
  • System Security Plan (SSP) and POA&M development
  • Remediation and ongoing managed compliance
  • Government-grade environments for handling CUI

A clean separation

We work alongside an independent assessor for the certification itself — keeping that separation clean is part of doing this correctly, and it's what the rules require. KeyStone gets you ready; an accredited C3PAO certifies you.

The CMMC Client Advisory

A clean, two-page summary of what CMMC means, the three levels, the deadline, and the steps to take. Share it with your leadership team.

Download PDF

FAQs

Frequently Asked Questions

Does CMMC apply to my business?
If your company does any work for the U.S. Department of Defense — as a prime contractor or anywhere in a supplier's chain — and you handle federal contract information or controlled unclassified information (CUI), CMMC affects your ability to win and keep that work. If you touch CUI, assume Level 2 applies.
What's the deadline I need to know?
November 10, 2026. The CMMC rule has been in effect since November 10, 2025 (when Level 2 self-assessments became required), but November 10, 2026 is the point at which most contracts involving controlled information will require an independent, third-party certification before the work can be awarded.
Which CMMC level do I need?
Level 1 is for basic Federal Contract Information and is self-assessed once a year. Level 2 is for Controlled Unclassified Information (CUI) and requires an accredited third-party assessor (a C3PAO) — most contractors land here. Level 3 covers the most sensitive information and is assessed by the government directly. It usually comes down to whether you handle CUI.
How long does certification take?
Commonly 12 to 18 months. Between the gap assessment, building your documentation, remediating findings, and the assessment itself, this is a months-long effort — which is exactly why the time to start is now rather than next year.
Doesn't my SOC 2 certification make me CMMC-ready?
Not by itself. Existing certifications like SOC 2 help — many of the underlying controls overlap — but they are not the same thing. CMMC has its own specific requirements built on NIST SP 800-171, and you have to prove compliance against those.
Can one company fix my gaps and also certify me?
No. That's a conflict of interest the rules prohibit. The organization that helps you get ready and the accredited assessor that certifies you must be separate. KeyStone handles readiness; we work alongside an independent assessor for the certification itself.
What documentation does CMMC require?
At Level 2 you need a documented System Security Plan (an SSP) describing how you meet the 110 required controls, plus a Plan of Action and Milestones (a POA&M) for anything not yet fully in place. KeyStone helps you build and maintain both.
How does KeyStone help with CMMC?
We help you get ready and stay ready: assessing where you stand today, building the security plan and documentation the assessment requires, putting the right protections in place, and managing them over time so you stay compliant after you're certified. We work alongside an independent assessor for the certification itself.

Based on the DoD CMMC program (DFARS rule effective Nov 10, 2025; Level 2 third-party certification phasing in Nov 10, 2026). Source: dodcio.defense.gov/CMMC. This guide is general information, not legal or compliance advice — your specific path depends on your contracts and the data you handle.

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