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As we move into 2026, small businesses, which make up the majority of companies in the Defense Industrial Base (DIB), are now required to meet CMMC compliance requirements on Department of War/Defense (DoD) contracts. This article will summarize the key CMMC challenges that government contractors will encounter as they strive to achieve their CMMC certification.
Understanding Changing Compliance Requirements
CMMC 2.0 is already complex enough with 110 security practices in NIST SP 800-171 and 320 assessment objectives, but compliance requirements will become more rigorous as this demanding cybersecurity standard rolls out through 2028. For example, although companies may be able to manage by only fulfilling CMMC Level 1 requirements in the near term, security experts note that the majority of government contractors will have to meet CMMC Level 2 mandates if they want to continue their participation on DoD contracts. The DoD is also continuously changing its compliance guidance and demands on new and existing contracts.
A key distinction in meeting Level 1 vs. Level 2 CMMC requirements is the necessity for third-party audits from designated assessment companies called C3PAOs as opposed to security self-assessments. In short, meeting CMMC requirements will become more challenging going forward and will demand an increasing amount of time, attention, and resources.
It is also important to note that security experts are predicting that more federal government agencies will soon require CMMC certification on their contracts. Thus, if your company plans to work with any federal government agencies, it is advisable to work toward obtaining CMMC compliance.
Scoping, Documentation, and Assessment Complexity
When small businesses begin their CMMC efforts, one of their most difficult challenges will be properly defining the scope of their systems that manage Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). Frequently, companies will overscope by including unnecessary systems, which dramatically increases the cost and complexity of compliance efforts. Alternatively, companies will make the mistake of underscoping, by not including critical systems, which results in noncompliance and security risks.
In addition, companies will also encounter difficulty in developing and executing a system that produces the required policies, procedures, and assessment evidence necessary to pass an official evaluation. Government contractors often don’t allocate sufficient resources to build and maintain audit-ready documentation.
Even after implementing the necessary technical controls for CMMC, companies often fail in developing effective methods to collect evidence for the 320 assessment objectives required at Level 2.
Internal and External Resource Limitations
In order to meet CMMC compliance requirements, government contractors will need to utilize skilled resources to implement controls in access management, network segmentation, and evidence collection and documentation. Budgets are normally tighter for small businesses, and the cost for any additional employees with expertise in CMMC would be considerable. Training current employees in these skills would also be expensive.
In addition, small businesses will face challenges finding timely audit appointments with certified C3PAOs because of a combination of a small pool of these specialized companies and a rapidly increasing demand for their services. These factors will create bottlenecks that could result in small businesses waiting months to get their mandatory assessments completed. This serious issue could cost an organization more time and resources and potentially result in lost contracts.
Consult with a CMMC Expert
In the face of these significant challenges, your organization should not attempt to achieve CMMC compliance without the valuable assistance of an experienced CMMC expert like Network Depot.
Your reliable CMMC partner will work closely with you to help you obtain a CMMC certificate customized to the required compliance level. They will help you with compliance scoping and determine whether your company should use the Enclave or Enterprise approach to reach your designated CMMC level.
Your trusted IT compliance partner will quickly identify and remediate any cybersecurity gaps and assist you in achieving successful CMMC self-assessments or third-party C3PA0 audits. They will also implement robust procedures and policies as well as install the powerful tools that will make your organization CMMC compliant and ready for DoD contracts. Your IT partner will also recommend the investments in technology and resources needed to maintain compliance in the face of planned and unplanned changes in the federal government contracting environment.
Contact Network Depot today and learn how they can effectively guide your company to CMMC certification.
