CMMC Compliance Checklist for Audit Level Readiness Assessment & Requirements
Businesses bidding for and delivering DoD (Department of Defense) contracts with CUI (Controlled Unclassified Information) & FCI (Federal Contract Information) require certification under CMMC. There are certain compliance requirements that organizations need to fulfill to prepare themselves for getting the certification. So, to make things easier, here we’ve discussed the CMMC compliance checklist.
Let’s first understand the meaning of CMMC compliance.
What is CMMC Compliance / Audit?
When we talk about Cybersecurity Maturity Model Certification or CMMC, a lot of questions we may hear;
1. Why CMMC was created?
2. What is my CMMC level?
3. What is a CMMC audit & does my business need it?
4. What is the CMMC roadmap to attain the certification?
5. Does my business meet the compliance requirement?
Before going deep into the discussion to find out the answers, let’s first understand what CMMC means.
Cybersecurity Maturity Model Certification or CMMC identifies different levels of maturity in the field of cyber security. The level depends on the sensitivity of the information you handle. The more information is sensitive, the greater the cyber maturity you are expected to present.
In short, CMMC compliance is an assessment standard to ensure defense contractors comply with cybersecurity needs.
What are Different CMMC Compliance Levels?
Depending on CMMC models, different levels are categorized. For instance, CMMC 1.0 model consists of 5 CMMC levels and CMMC 2.0 consists of 3 levels of CMMC. These levels are nothing but a set of cybersecurity practices and standards designed to protect national security by aligning how Defense contractors and subcontractors handle FCI and CUI.
Furthermore, each CMMC certification level has its own processes, practices, and assessment procedures. And that is briefly shown in the below image.
Why Businesses Need to Fulfil CMMC Audit Compliance Requirement?
Whether the business size is small, medium, or large, every organization should be CMMC compliant and they should follow a readiness checklist. Because it’ll help them;
- Protecting sensitive information
- Enhancing overall cybersecurity hygiene
- Confidently mitigating evolving threats
- Maintaining public trust through professional standards
- Infusing the combination of cybersecurity & cyber resilience
Above all, the checklist will help protect CUI, the information that the government creates and possesses. Apart from CUI, CMMC compliance requirement is stressed to safeguard the FCI as well. So, directly being CMMC compliant benefits the entity or business that handles the information on behalf of the government.
CMMC Compliance Checklist – Know the Process to Complete Audit Requirement
CMMC compliance is required to sustain the cybersecurity hygiene of the organization. Here is the checklist you can follow to prepare your organization for compliance.
1. Involve Internal Stakeholders – The First Step of Compliance Requirement
- Outsourced IT teams need to be involved to ensure security controls are implemented and maintained.
- You need a legal team to ensure CMMC compliance in DoD contracts.
- The HR team is needed to review current employee policies. And, from time to time update them to be on the same page with CMMC requirements.
- You need a finance team to ensure that any expenditures related to CMMC compliance are budgeted, given top priority, and taken into account.
2. Perform Gap Analysis for CMMC Audit
Identifying gaps is the 2nd step of the CMMC compliance checklist. Locate any probable issues that may arise when applying new processes or procedures by performing a readiness assessment. Before an assessment, evaluate the current state of your IT infrastructure.
3. Determine The CMMC Compliance Level
It’s necessary to determine the CMMC level of compliance the organization needs before preparing for the audit. So, you need to decide whether your organization needs Level-1, Level-2, or Level-3 certification. Determining the level depends on what type of information your organization handles.
For instance, if your company handles FCI then you must comply with CMMC level 1. And, if your company handles CUI then you must comply with CMMC level 2 or 3.
4. Decide The Scope Of Assessment to Achieve CMMC Compliance
Now comes the 4th step of the CMMC audit checklist. To become CMMC assessment ready, it’s essential to determine the scope and that depends on 3 factors;
- You need to specify what categories of data (FCI, CUI, or both) your organization has.
- In your organization, where the data is processed, stored, or transmitted?
- How can you reduce the footprint of that data?
The above undertakings are vital to ensure that the organization is ready for assessment. However, if you are not sure how to execute and from where to start to determine the scope then reach out to SysTools’ CMMC consultants.
5. Identify Specific Areas of Security Controls for CMMC Compliance Requirement
The next step is to identify where your organization falls short in terms of compliance. And then start sourcing and implementing necessary cybersecurity controls to address those gaps.
Since detailed records or evidence of all security measures implemented in your company is important, keeping and maintaining the same is essential.
6. Create a Plan of Action and Milestone CMMC Checklist
A Plan of Action & Milestone or POAM is a document that gives an idea of specific steps your organization needs to take to remediate any security insufficiency identified in the gap analysis. This will not only be helpful for tracking your progress but also serve as proof of self-assessment.
7. Conduct The Assessment With The Help of C3PAO for CMMC Compliance
The 7th step of the CMMC compliance checklist includes Companies operating in the defense supply chain must complete a CMMC audit conducted by Third-party Assessment Organization (C3PAO). Organizations Seeking Compliance (OSC) require to conduct a CMMC assessment. Hence, it’s the responsibility of the company to hire a professional C3PAO.
8. Initiate Internal Review for CMMC Compliance
Once you conduct the CMMC assessment successfully based on the desired maturity model level, you should have a list of documents or processes that you may have to create or update based on priority.
Stay Ahead of CMMC Compliance Requirements
Recently CMMC 2.0 is introduced and by 2026 all contractors that do business with DoD must comply with the cybersecurity maturity model. CMMC is evolving & updates are being made. So, plan ahead the time needed to focus efforts on readiness by referring to the CMMC compliance checklist.
Q. What is CMMC 2.0 Compliance?
CMMC 2.0 is a complete framework to protect defense industrial bases’ sensitive and unclassified information from cyberattacks. It implements a tired approach to assess requirements depending on the sensitivity of the information.
Q. Why CMMC 2.0 introduced?
The 2.0 model was introduced to bring changes to the tired model of CMMC certification levels. The changes will focus on protecting all points in the DoD supply chain. As a result, it’ll facilitate the ability of organizations to counter emerging security threats.
Q. How my organization will get benefit from CMMC compliance?
CMMC audits help boost the organization’s cybersecurity, reputation, and business opportunities, while also mitigating the risks associated with cyber threats. With this organizations can enhance their security posture and protect confidential information from cyber threats.
Q. CMMC compliance requirement – How often does one need to conduct audits?
The frequency of audits completely depends on several factors such as the level of CMMC certification your organization is seeking, the requirements of your industry, etc. That’s why it’s important to work with qualified cybersecurity professionals who can provide guidance on how often you should conduct assessments.
Q. Is there any way to know what CMMC level is required for a contract?
You can determine the required CMMC level for a contract by reviewing the contract documentation, communicating with the contracting agency, and understanding the nature of the contract itself.
Q. Who needs to be CMMC Compliant?
Any organization that handles confidential government data including prime contractors and subcontracts at various levels needs to be compliant with CMMC.
Q. What are the CMMC Level 1 requirements?
The level 1 of CMMC requires the defense contractors to fulfill basic cyber hygiene. The level 1 sets the foundation for the higher levels.
Q. Does CMMC require an audit?
Yes. CMMC requires an audit for any organization in the DIB (Defense Industrial Base).
If you are in any doubt about how to navigate between the steps mentioned in the checklist then contact our CMMC auditors team now.