What Are CMMC Level 2 Requirements and How Do They Affect Your Business?
- Cybersecurity Consultant Brent Gallo
- Sep 19
- 3 min read
As the Department of Defense (DoD) rolls out the Cybersecurity Maturity Model Certification (CMMC) program, contractors and subcontractors across the defense industrial base (DIB) must prepare for stronger cybersecurity requirements tied directly to federal contracts. Beginning November 10, 2025, CMMC requirements will start appearing in new DoD solicitations. If your organization works with the DoD or even supports a prime contractor you need to understand what’s required to stay eligible.
What Is CMMC Level 2?
CMMC Level 2 applies to organizations that handle Controlled Unclassified Information (CUI). Level 2 certification aligns directly with the security requirements in NIST SP 800-171 (“Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations”).
110 Security Requirements: CMMC Level 2 encompasses the same 110 requirements outlined in NIST 800-171 Rev. 2.
Assessment and Certification: Unlike Level 1 (Foundational), Level 2 requires an independent third-party assessment performed by a CMMC Third-Party Assessment Organization (C3PAO) before certification is awarded.
From Requirements to Implementation
The technical backbone of CMMC Level 2 is NIST 800-171A, which provides the assessment objectives for each requirement in 800-171. These objectives aren’t simply checkboxes—they define what evidence and artifacts must exist for an assessor to validate compliance.
Each security requirement must be implemented with a combination of controls:
Technical Controls: Firewalls, endpoint detection and response (EDR), multifactor authentication (MFA), encryption, vulnerability management.
Administrative Controls: Policies, procedures, training, access approvals, supply chain oversight.
Physical Controls: Facility access restrictions, badge systems, secure storage, surveillance, and environmental safeguards.
An effective program doesn’t rely on one layer, it weaves all three into a holistic cybersecurity posture that’s documented, monitored, and continuously improved.
How Do You Know if CMMC Applies to You?
The simplest way: check your contracts.
- If your DoD contract references handling CUI, you must meet CMMC Level 2.
- If you are a subcontractor, your prime contractor may flow down CMMC requirements to you in order to remain compliant.
- Even if you don’t believe you directly handle CUI, review the Statements of Work (SOWs), DD254s, and flow-down clauses, many organizations discover CUI requirements buried in task orders or subcontracts.
The DoD emphasizes that CMMC applies to all organizations in the defense supply chain that process, store, or transmit CUI. If you’re unsure, assume you need to prepare.
Resources:
NIST SP 800-171 Rev. 2: https://csrc.nist.gov/pubs/sp/800/171/r2/upd1/final
DoD CMMC Program Overview: https://dodcio.defense.gov/CMMC/About/
DoD CMMC Resources & Documentation: https://dodcio.defense.gov/CMMC/Resources-Documentation/
The Path to Certification
1. Scoping: Identify the systems, networks, and processes where CUI is stored, processed, or transmitted.
2. Gap Analysis: Map current practices to NIST 800-171 requirements and identify deficiencies.
3. Remediation & Implementation: Deploy technical, administrative, and physical controls to close gaps.
4. Mock Assessment: Conduct an internal or consultant-led dry run using NIST 800-171A assessment objectives.
5. C3PAO Assessment: Engage with an authorized C3PAO for the official evaluation. Passing the assessment leads to certification.
Why You Need to Act Now
CMMC Level 2 certification isn’t a quick checkbox—it’s a programmatic change. Depending on the size of your organization and complexity of your systems, full implementation may take months. With CMMC enforcement beginning November 10, 2025, waiting until a contract requires it could cost you valuable opportunities.
How Hire A Cyber Pro Can Help
At Hire A Cyber Pro, we serve as your trusted CMMC consultant and guide:
Scoping: Defining the boundaries of your CUI environment.
Implementation: Developing policies, deploying security tools, and building compliance documentation.
Mock Assessments: Practicing against the NIST 800-171A objectives before the real C3PAO arrives.
Continuous Support: Maintaining compliance and preparing for annual affirmation.
Don’t risk losing DoD opportunities because you weren’t ready. Start now, let Hire A Cyber Pro help you build a robust cybersecurity program and position your organization for CMMC Level 2 success.📞 Contact us today to begin your path to certification.
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