CMMC Is a Cybersecurity Maturity Journey, Not a Certification Event
The Cybersecurity Maturity Model Certification (CMMC) did not appear overnight. It grew out of a broader federal effort to standardize how sensitive but unclassified information is identified, handled, and protected, beginning with Executive Order 13556 and the establishment of the Controlled Unclassified Information (CUI) program.
Since then, CMMC has gone through a lengthy maturation process involving industry feedback, formal rulemaking, agency oversight, professional credentialing, and the development of an assessment ecosystem. While many organizations were not completely caught off guard by this direction, many are now actively working through the practical realities of compliance as the Department of Defense’s program continues to shape cybersecurity expectations across the Defense Industrial Base (DIB).
What CMMC Is Intended to Protect
At its core, CMMC is intended to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) that is processed, stored, transmitted, or supported by contractor systems.
The model includes three maturity levels, with increasing expectations based on the sensitivity of the information and the risk associated with the contract. For many organizations, the most significant effort is at Level 2, which aligns to the 110 security requirements in NIST SP 800-171.
These requirements are not just paperwork obligations. They represent operational cybersecurity practices involving access control, incident response, configuration management, risk assessment, audit logging, media protection, system integrity, and other areas that must be implemented, documented, and sustained over time.
Treat CMMC as a Deliberate Improvement Process
Organizations should not be frightened by the governance, documentation, and compliance aspects of CMMC, but they should be honest about where they are today and the level of effort required to reach the desired end state.
CMMC is not an “easy button” activity that can be completed responsibly in a few days or weeks. It takes time to define the environment, understand where FCI and CUI reside, establish policies and procedures, implement technical controls, collect evidence, train personnel, and normalize repeatable security practices.
There are many free and reputable resources available, including Executive Order 13556, the CMMC rulemaking materials, and The Cyber AB. The best approach is to treat CMMC as a deliberate cybersecurity improvement process, not simply a certification event. A strong culture of cybersecurity is built through consistency, accountability, and practical control ownership over time.
If your organization is on the journey to compliance or is considering a higher level of maturity, do not forget to check out The Cyber AB Marketplace for a consolidated listing of CMMC professionals at your disposal.
References
Darold Froemming
Director, Client Cyber Strategy