Understanding the Core CMMC Compliance Requirements

CMMC or the Cybersecurity Maturity Model Certification is a fresh set of compliance requirements that all contractors and organizations aiming to secure federal contracts need to meet. To achieve CMMC compliance, contractors will have to allow the U.S. Department of Defense (or their representatives) to vet their IT systems. The aim is to install the best cybersecurity measures. The stronger your IT system’s cybersecurity standards, the likelier you are to gain access to Controlled Unclassified Information (CUI) and privileged federal contract Information.

By 2026, everyone aiming to do business with the Pentagon will need to abide by CMMC standards. For now, the CMMC will impact DoD contractors who are already complying with federal regulatory guidelines for securing sensitive government information on their systems. The ways in which they secure sensitive data need to be CMMC-compliant.

The Fundamentals of CMMC Certification

Pervious security standards such as the NIST SP 800-171 or the DFARS 252-204-7012 haven’t been strong enough to thwart the constant cybersecurity threats that organizations in possession of sensitive government information face. The Federal government experienced over eighty cybersecurity breaches in 2019, which exposed over 3.6 million sensitive government records.

The technology used by international cyber criminals has advanced rapidly in the past three years, and standards like the NIST SP 800-171 or the DFARS 252-204-7012 just aren’t strong enough to prevent these criminals from targeting vulnerable DoD contractors and affiliates.

That’s why the CMMC has modeled five different maturity levels for contractors. Each maturity level is harder to accomplish since not all contractors are given access to sensitive government information. Here are the levels

The First Level

The requirements in the first level of CMMC is similar to the requirements presented in the FAR Clause 52.204.21. Basic cybersecurity measures such as limiting the types of transactions made on a computer system or ensuring government data are destroyed properly after a contract has been concluded are covered at this level.

Overall, there are seventeen basic security requirements that contractors and organizations need to meet to be ‘Level 1 compliant.’ They include –

• Using anti-virus and malware software.  

• Using complex passwords to encrypt files containing government information.

• Total implementation of all the seventeen NIST SP 800-171 controls (revised version). Most contractors are already abiding by the NIST SP 800-171 standards.

• Proper organization of all incident reports.

• Installing basic data security measures.

The Second Level

Level 2 is very different from Level 1 as contractors in this level need to deal with Controlled Unclassified Information (CUI). Here are some key details about Level 2 of CMMC compliance –

• Level 2 has 55 more practices than Level 1 (72 practices in total)

• Contractors who want to qualify for Level 2 CMMC compliance must have a well-documented history of adhering to the strongest cybersecurity practices.

• Contractors also need to demonstrate situational awareness about cybersecurity threats in their audits.

• Contractors must have proper risk management assessment models to display during the audits.

• Proper business continuity and data back-up measures must be put in place in case there are security hacks.

The Third Level

As per the CMMC guidelines, if a contractor or organization attains level 3 compliance, it has “good cyber hygiene practices.” Here are some key details about Level 3 of CMMC compliance

• All measures mentioned in the NIST SP 800-171r1 need to be implemented to be ‘level 3 compliant.’

• There is a total of 130 practice requirements in level 3, 58 more than level 2.

• Contractors need to record every security measure they take, right from level 1.

• They also need to create detailed plans documenting their plans for staying compliant in the long-run. 

• Contractors must have multi-factor authentication systems on their devices.

• They must inform stakeholders about potential cybersecurity threats consistently.

The Fourth Level

The fourth level compels contractors to re-assess their cybersecurity measures and establish detailed response measures to address evolving cybersecurity threats. Here are some key details about Level 4 of CMMC compliance – 

• There’s a total of 156 practice requirements, 26 more than level 3.

• Organizations and contractors need to constantly share their findings regarding security threats with the DoD’s management teams.

• Installation of the most cutting-edge cybersecurity tools is mandatory.

• Include mobile devices in their cybersecurity policies.

• Invest in proactive cyber-threat detection tools.

• Have a segregated data network.

The Fifth Level

At the final level, contractors need to first ensure they’ve addressed all cybersecurity requirements from Levels 1-4. Here are some other key details about Level 5 of CMMC compliance –

• Contractors will have to go through at least four audits to attain Level 4 compliance as per the CMMC standards. 

• They need to demonstrate their cybersecurity tools’ efficiency against advanced and persistent cybersecurity threats.

• All members of the contracting team or the organization need to follow a standardized, documented approach when it comes to cybersecurity.

• Install a security operations center that’s active 24X7.

• Contractors need to invest in device authentication and real-time tracking tools.

How to be prepared for the audit? The first round of Request for Proposals and audits rolled out back in September 2020. Leading contractors and businesses have already started partnering with consultants who are experts of CMMC compliance requirements to prepare for their upcoming CMMC audits. All contractors and organizations aiming to land lucrative DoD contracts must do the same, as attaining CMMC compliance won’t be easy.

The CMMC is by far the most robust cybersecurity framework ever launched by a public organization. It covers all security requirements for federal contractors into a single expedient structure. Previous certification standards were either inefficient or extremely complex. The CMMC attempts to build on past standards like the NIST SP 800-171, the NIST SP 800-53, the DFARS 252-204-7012, and the ISO 27001.