Getting CMMC certified involves more than implementing controls - you need to find a C3PAO, prepare an evidence package and understand what happens when gaps are discovered during the assessment.
As of 2026, Level 2 certifications require assessment by a CMMC Third-Party Assessment Organization (C3PAO) listed on the Cyber-AB marketplace. Level 3 certifications go through DIBCAC. Self-assessments apply only to Level 1 and certain Level 2 contract, so be sure to check your contract solicitation language to confirm which applies.
Start with scope. What systems process, store, or transmit CUI? That boundary defines your System Security Plan (SSP) perimeter. Scope creep is one of the most common reasons organizations pay more than expected or fail assessments. Segment CUI off whatever systems you can before the assessment begins.
C3PAOs assess against NIST SP 800-171A Assessment Objectives (AOs), not just the 110 controls. There are over 300 AOs. Each one needs documented evidence through policies, logs, screenshots, configuration exports, training records. A control with no supporting evidence is likely to be scored as not met.
Submit your SPRS score honestly before engaging a C3PAO. A knowingly inaccurate SPRS score is a potential False Claims Act liability. Assessors will verify your self-assessed score against observed evidence, so optimistic scores create problems rather than solving them.
Engage a C3PAO early since many organizations schedule assessments 6 to 12 months after starting remediation work. During the assessment (typically 3 to 5 days), gaps that cannot be addressed immediately become findings. Minor deficiencies may qualify for a POA&M extension at the contracting officer's discretion, but significant unresolved gaps will result in a conditional or failed assessment.
