The Department of Defense (DoD)’s Cybersecurity Maturity Model Certification (CMMC) is operational, with compliance assessments already underway. Yet, it’s surprising that numerous defense contractors still don’t prioritize CMMC certifications.
As compliance is mandatory for all Defense Industrial Base (DIB) entities, now’s the best time to schedule CMMC assessments.
However, there are several pitfalls to contend with. You must skillfully navigate these challenges to expedite the certification process.
Fortunately, you don’t have to fly into CMMC headwinds unprepared. Not when you can tap into professional expertise and bypass common pitfalls experienced by many Organizations Seeking Assessment (OSAs).
Here are seven cybersecurity lessons we can learn from C3PAO’s protocol expertise on how to streamline the CMMC certification process.
Who Are C3PAOs?
CMMC third-party assessor organizations (C3PAOs) are independent agencies mandated to conduct Level 2 CMMC assessments.
A C3PAO plays an instrumental role in ensuring all Level 2 DIBs adhere to applicable cybersecurity requirements for safeguarding CUI. The agencies are vetted and accredited by the Cyber Accreditation Body (Cyber AB).
7 Cybersecurity Lessons From C3PAO Protocol Experts
1. C3PAOs Are Fewer Than You Think
As of August 2025, there were approximately 80 fully authorized CMMC C3PAOs against thousands of OSAs.
For perspective, the DIB comprises over 100,000 entities. Most of these will require C3PAO-led assessments to defend their CMMC certifications in line with the newly revamped program.
That means most C3PAOs are probably already booked. If you skimp on assessments, you may find the queue longer than you anticipated.
2. Prepare Early or Contend with Long, Slow-winding Queues
Now that we’ve underscored the significance of prioritizing C3PAO audits, you’re probably wondering how far back you can start your preparations.
A good practice is to prepare for Level 2 assessments about 9 – 12 months in advance. This is a reasonable period to scope your organization and seal any security weaknesses.
Besides, you can set aside a suitable budget, allocate responsible assessment personnel, and find an accredited C3PAO long before your mandated assessment deadline.
- Locate and Tag the CUI in Your System
C3PAOs are typically authorized to conduct Level 2 audits. They focus on ensuring defense contractors adhere to the CMMC standards for safeguarding Controlled Unclassified Information (CUI).
Before scheduling a C3PAO-led assessment, it’s important to know where the CUI resides in your systems. CUI exists fundamentally on defense contract forms.
These could be physical or electronically generated contracts. You can also find CUI in your structured data storage systems, including cloud storage.
Wherever the information resides, find it, create a robust inventory, and label it accordingly. Portion markings, digital watermarks, and data categorization are some CUI tagging techniques you can deploy.
4. CUI Access Should Be On a Need-to-Know Basis
After locating the CUI in your system, the next logical step is to restrict who can retrieve it. Note that access control is a critical requirement that C3PAOs evaluate during Level 2 audits.
Several access control best practices exist, including multifactor authentication (MFA).
MFA uses multiple verification layers to grant access to your CUI. It’s a step up from standard password-based protocols, which hackers can crack with remarkable ease.
More importantly, access should only be on a need-to-know basis.
5. Label FCI Too
The three CMMC 2.0 maturity levels vary principally on the information type that each seeks to protect.
CUI applies to both Level 2 and 3 businesses. The difference is that Level 3 seeks to safeguard high-sensitive CUI with a view to averting Advanced Persistent Threats (APTs) across the defense supply chain.
Meanwhile, Level 1 DIBs must implement cybersecurity controls that protect the Federal Contract Information (CUI) in their systems.
FCI is a class of CUI that you can safeguard using foundational cybersecurity practices. This information class requires tagging too, especially since you must obtain Level 1 certification before applying for Level 2 assessments.
- Don’t Discount Employee Training
Not all defense contractors can afford to maintain full cybersecurity teams. But even if you must outsource these personnel, it’s important to train your regular employees on the significance of CMMC compliance.
CMMC education should be a fundamental part of your onboarding processes. Besides, you can complement these initial programs with ongoing training.
Remember to model each program after an employee’s roles. Some key focus areas would be phishing awareness, APT detection, incident reporting protocols, and risk mitigation measures.
7. Always Verify Stakeholder Compliance
Obtaining CMMC Level 2 compliance isn’t enough. To protect your supply chain, you must validate that your stakeholders equally adhere to relevant cybersecurity protocols.
First, you’ll need to thoroughly map your supply chain for CUI-handling entities. Then, verify that those vendors meet the applicable CMMC requirements.
This is particularly recommended where you’re either subcontracting DoD contracts or working with external service providers (ESPs).
And just as the DoD expects ongoing CMMC compliance, you should implement robust cybersecurity measures to safeguard your supply chain in the long run.
Wrap Up
Working with a C3PAO is key to navigating common CMMC assessment pitfalls. It’s a critical step towards accelerating the certification process, which can take months depending on your company’s scale and niche.
However, not every C3PAO is worth their salt.
Insist on an auditor with full Cyber AB authorization to offer CMMC assessments. It’s also best to choose an agency that’s familiar with your stack, and preferably one with verifiable experience auditing businesses in your niche.
Other critical metrics when scouting for a reputable C3PAO include cross-industry assessment, quality assurance guarantee, clear work methodology, and competitive assessment fees.
