If your organization works with the U.S. Department of Defense (DoD) – either as a prime contractor, subcontractor or supplier in the defense industrial base – you’re almost certainly aware of the CMMC framework. But awareness isn’t enough. With the compliance clock ticking, proactive preparation is no longer optional.
Why CMMC matters
CMMC is the DoD’s program to ensure that defense contractors and their suppliers meet specific cybersecurity standards to protect:
- Federal Contract Information (FCI) – unclassified but non-public government contract info.
- Controlled Unclassified Information (CUI) – unclassified information that is nonetheless sensitive or subject to safeguarding/dissemination controls.
In short: if you handle FCI or CUI as part of your DoD work, you’ll need to align with CMMC requirements (controls, assessments, documentation). Failure to get/maintain certification may mean losing eligibility to bid on or maintain DoD contracts.
Key upcoming deadlines & rollout
- The CMMC Program Rule (32 CFR) went into effect December 16, 2024.
- The Acquisition Rule (48 CFR) which enables the DoD to put CMMC requirements into contracts was published September 10, 2025, and becomes enforceable ~60 days later (around November 10, 2025).
- After that: CMMC requirements will begin appearing in new contract solicitations. Phase 1 will require Level 1 or Level 2 (self-assessment) in many cases; later phases will require third-party assessments and ultimately Level 3 for the most sensitive work.
The fundamental takeaway: waiting until the “last minute” is a high-risk strategy. Many companies require 6-18 months of preparation.
What you must do: A Compliance Roadmap
Here is a high-level action plan that organizations must execute to meet CMMC compliance and stay eligible for DoD contracts:
1. Determine Your Required Level
- If you handle FCI only → likely CMMC Level 1 (basic safeguarding, ~15 controls).
- If you handle CUI → likely CMMC Level 2 (110 controls, based on NIST SP 800-171).
- If your work involves very high-risk/critical national security data → Level 3 (advanced controls including selected NIST SP 800-172) may apply.
2. Conduct a Gap Assessment / Readiness Audit
- Baseline your current cybersecurity controls, policies, documentation, system boundaries, and determine what you already have versus what you must implement.
- Identify where you process/store/transmit CUI (your “CUI boundary”) and limit scope if possible to reduce cost/complexity.
3. Develop a Remediation Roadmap
- Prioritize implementing the missing controls (technical, administrative, physical) required by the level you need.
- Establish timelines, budgets, ownership, and define how you’ll evidence compliance (logs, policy, monitoring, training).
- If there are gaps you cannot immediately remediate, plan for a POA&M (Plan of Action & Milestones) where permitted (Level 2 & 3 allow POA&Ms; Level 1 does not).
4. Implement the Controls & Produce Documentation
- Deploy multi-factor authentication (MFA), endpoint protection, encryption, access controls, network segmentation, monitoring, incident response, etc.
- Create/maintain your System Security Plan (SSP), Incident Response Plan, training records, policy documents, continuous monitoring plan, etc. (documentation matters).
5. Perform Assessment / Certification as required
- For Level 1: Annual self-assessment and senior executive affirmation.
- For Level 2: Either self-assessment or third-party assessment (depending on contract), every three years; plus annual affirmation.
- For Level 3: Third-party “expert” assessment (e.g., via Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)) every three years.
6. Maintain Ongoing Compliance & Monitoring
- Certification is not a one-and-done task. You must continuously monitor, test, update, and document your security posture. Changes to processing/storage location, system architecture, or subcontractor relationships can affect your compliance status.
- Stay ready for audits, re-certification timelines, and contract renewal or option exercises.
Risk of Missing the Deadline
- If you don’t meet the required CMMC level when the clause appears in a solicitation, you may not be eligible for the award.
- A poor or missing remediation path can jeopardize your contract pipeline and damage relationships with primes or the DoD.
- Because assessments and assessor capacity are limited, the scramble to “get ready” late may lead to longer wait times or higher costs.
How MC Services Can Help You Get CMMC-Ready
At MC Services, we understand the intersection of technical infrastructure (Windows Server, Linux, Ubuntu, virtualization, cloud), documentation/policy, and the regulatory burden that organizations face in the defense supply chain. Here’s how we can partner with you:
1. Gap Assessment & Readiness Planning
- We conduct a comprehensive readiness assessment aligned with your required CMMC level (Level 1/2/3) and your specific environment (servers, virtualization, cloud, endpoints, network).
- We identify your CUI/FCI boundary so you can focus remediation efforts efficiently.
- We deliver a detailed roadmap: what controls to implement, in what sequence, who is responsible, estimated budget, timelines.
2. Control Implementation & Architectural Support
- Given our deep expertise in Windows Server, Ubuntu/Linux, virtualization (ESXi), network segmentation, identity & access, etc., we help you deploy the technical controls (MFA, endpoint detection, network monitoring, segmentation, encryption, log management, STIGs, hardening) required for CMMC.
- We help craft and implement policies, procedures, and documentation (SSP, incident response, user training, change management) aligned with CMMC requirements.
- We assist with integration of tools (patch management, vulnerability scanning, SIEM/EDR) and help build a sustainable operations model.
3. Documentation & Evidence Preparation
- We help you compile the necessary artifacts that assessors will expect (logs, vulnerability scan results, training records, change records, architecture diagrams, user access lists, evidence of monitoring).
- We maintain your documentation so that you’re always audit-ready—reducing “surprise” gaps when a contract requires certification.
4. Assessment Support & Post-Certification Maintenance
- We support you during the assessment process: we coordinate with your assessor (or help select one), prepare your team for interviews, review the readiness of your evidence, and help remediate any “not met” findings via Plan of Action and Milestones (POAM) if permitted.
- After certification, we operate as your compliance partner: conducting periodic reviews, updating controls when infrastructure changes, ensuring your status remains valid and your DoD contract eligibility is maintained.
5. Tailored for Your Infrastructure Complexity
Whether your environment includes:
- On-prem Windows Server clusters, virtualized via ESXi
- Ubuntu/Linux servers hosting web services, WordPress, custom apps
- Hybrid cloud and local infrastructure
- Identity management via Azure AD/Entra
- A mix of internal IT services and external client hosting functions
MC Services has the hands-on experience to align the technical control requirements of CMMC with your real-world infrastructure.
Final Thoughts & Call to Action
The time to act is now. With the CMMC contractual requirements beginning to roll out November 2025 and beyond, starting early gives you the advantage—not the panic.
MC Services stands ready to guide you through each step. Let’s set up a complimentary readiness consultation so you can understand and determine your level of compliance
