December 8, 2025

Last Updated on December 11, 2025

The CMMC Final Rule (48 CFR) is in effect as of November 10, 2025, and the US Department of Defense (DoD) is adding CMMC requirements to RFPs, RFIs, and contracts. Businesses that waited to start their compliance efforts must now jump on the fast track or risk losing current contracts as well as future business opportunities.

What can US defense industrial base (DIB) orgs do to accelerate their CMMC readiness timeline? This article shares suggestions for reducing CMMC compliance and certification time, effort, and cost.

Key takeaways

  • Most companies that have not met NIST 800-171 compliance per current DoD requirements need 6 to 18 months to get their CMMC certification. Factors like target CMMC level, current controls, number of locations, and available resources all influence your timeline.
  • Businesses that handle controlled unclassified information (CUI) need to protect it at CMMC Level 2, which includes an independent audit of all 110 controls in NIST 800-171 Rev. 2—a high cybersecurity bar.
  • Some of the best ways to accelerate your CMMC Level 2 journey include carving out a “CMMC enclave,” automating compliance and governance processes, and engaging an expert partner.
  • Plans of Action & Milestones (POA&Ms) and conditional certification have many limitations as a way to put off full compliance.

How long does it take to become CMMC certified?

Most organizations need about 6 to 18 months to achieve CMMC compliance and certification. Top factors that can make a company’s CMMC journey longer or shorter include:

  • Your target CMMC level.
    Firms that handle controlled unclassified information (CUI) need to achieve CMMC Level 2, which includes a third-party audit of all 110 controls in NIST 800-171 Rev. 2. Whereas orgs that only handle federal contract information (FCI) but not CUI can self-attest to just 17 controls based on Federal Acquisition Regulation (FAR) clause 52.204-21. CMMC Level 3 takes the longest because it first requires CMMC Level 2 certification.
  • Your current cybersecurity program.
    The stronger your current cybersecurity posture, the less work required to achieve your target CMMC level.
  • Company size and complexity.
    The bigger your business, the more locations you have, and the more complex your IT infrastructure, the longer CMMC certification generally takes.
  • Resource/expertise availability.
    If you can prioritize CMMC compliance and dedicate skilled staff to reaching certification you can probably finish in less time.
  • Ability to schedule a CMMC Third-Party Assessor Organization (C3PAO) assessment.
    With thousands of DIB orgs needing CMMC Level 2 certification and only a limited number of C3PAOs, the availability of a C3PAO to perform your assessment could impact your timeline.

What does the CMMC Level 2 certification process look like?

At a high level, the CMMC Level 2 certification process has three major stages:

  1. Preparation and remediation.
    During this stage you assess your current cybersecurity controls in relation to NIST 800-171, implement the missing controls, develop the necessary plans and documents (e.g., a system security plan) and collect all the documentation you need to demonstrate compliance.
  2. Once you have the necessary controls and documentation in place, you can undergo a formal assessment with a C3PAO. This includes a readiness review of your documentation, an on-site assessment of your CMMC controls, and submission of an assessment report to the Cyber AB. The usual assessment timeline is 4 to 8 weeks.
  3. Based on your C3PAO’s report that your business meets all requirements, the Cyber AB awards CMMC Level 2 certification. If your assessment report includes a Plan of Action & Milestones (POA&M) to remediate gaps, you have up to 180 days to close the gaps.

What steps can we take now to accelerate CMMC Level 2 compliance?

To accelerate CMMC Level 2 compliance there are three basic approaches:

  1. Minimize the size and complexity of the environment you will certify as CMMC compliant.
  2. Add automation to simplify compliance and governance.
  3. Hire expert resources to help implement the right controls, tools, and documentation in an efficient, strategic way that aligns with business goals.

For many businesses, the single most important step you can take to help with CMMC Level 2 certification is to isolate all your CUI in a dedicated, secure environment—often called a CMMC enclave. This will reduce your compliance scope and cost versus certifying your entire network. However, an enclave is only viable if a relatively small percentage of your staff handle CUI. Otherwise, the path to less complexity and cost could be securing your full environment at CMMC Level 2.

A key step for many DIB orgs is to prioritize implementing the most critical controls first, such as multifactor authentication (MFA) for all systems that process CUI, end-to-end encryption for CUI, security awareness training for employees who interact with CUI, and event logging to support audit/accountability, incident response, etc.

Another early step should be getting started on your system security plan (SSP), incident response plan, and other required plans as these can be dynamic and time-consuming to create. Plus, they will be some of the first evidence an internal or external auditor will request. Maintain documentation and compliance data in a central location to simplify access for auditors and your team. Pre-filled documentation and templates can be helpful for those with enough expertise to use them optimally.

CMMC Level 2 also challenges DIB orgs to elevate not only their own cybersecurity, but also to take responsibility for their subcontractors’ compliance. Developing a third-party risk management (TPRM) program and assessing vendor risk and compliance is a significant undertaking. Don’t delay getting started on this initiative, which is mandated for CMMC compliance.

Avoid relying on POA&Ms and conditional certification

A POA&M document details tasks an organization must accomplish to remediate cybersecurity vulnerabilities and CMMC compliance gaps. It describes task milestones, required resources, and the planned completion timeframe, along with other information.

DIB orgs that meet most of the NIST 800-171 controls for CMMC Level 2 can use POA&Ms to maintain existing contracts and—once all POA&Ms are resolved within the 180-day deadline—move from conditional certification to full CMMC Level 2 certification. This ensures companies have enough time to implement all the CMMC 2.0 requirements and address open issues without losing current contracts.

But while POA&Ms can potentially buy limited time to bridge minor compliance gaps and help achieve conditional CMMC certification, this approach has significant drawbacks. These drawbacks include:

  • At the time of your third-party CMMC certification assessment, your C3PAO will permit only a limited use of POA&Ms relating to only select, less critical (1-point) controls.
  • You need to comply with the great majority of NIST 800-171 controls before even initiating your formal certification process with a C3PAO.
  • You need a minimum score of 88 out of a possible 110 (80%) to be eligible for a conditional CMMC Level 2 certification, irrespective of POA&Ms.
  • POA&Ms are valid only for CMMC levels 2 and 3, not CMMC Level 1.

You must resolve all POA&Ms within 180 days of receiving a conditional CMMC certification. If you created your POA&M during a self-assessment, your company can perform its own closeout assessment. If you created a POA&M based on findings from a C3PAO or other CMMC assessor, the original assessor will perform the closeout assessment, which could require an on-site visit and added costs.

In summary, the purpose of POA&Ms and conditional certification is to help DIB orgs that are well on their way to CMMC compliance keep their contracts while they quickly rectify a few minor issues. If you are missing any critical cybersecurity controls (worth 2 to 5 points), these are not eligible for remediation using POA&Ms. Similarly, if your total compliance score is below 88, you are ineligible for conditional certification.

Therefore, DIB orgs cannot count on POA&Ms to pass their CMMC Level 2 third-party audit. The best approach is to complete a rigorous self-assessment and report an accurate CMMC compliance score to the DoD. From there, you can assess whether POA&Ms might benefit your business as part of the formal CMMC certification process with a C3PAO.

What’s next?

Is your business ready for CMMC certification? No matter where you are today, our comprehensive assessment, implementation, and remediation support will ensure you efficiently meet all necessary CMMC requirements.

Contact CBIZ Pivot Point Security today to start a discussion with a CMMC expert.

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