Originally published 01/07/2025, updated content 10/30/2025.
Understanding what triggers the need for Cybersecurity Maturity Model Certification (CMMC) compliance is essential for organizations involved in federal contracts. If your business handles Controlled Unclassified Information (CUI) or works with the Department of Defense (DoD), meeting specific CMMC requirements is not optional—it’s mandatory. In this blog, we’ll break down the key triggers for CMMC compliance, explore its levels, and provide actionable steps to prepare for certification.
What Triggers CMMC Compliance?
CMMC compliance is triggered primarily by handling CUI or participating in DoD contracts. CUI refers to sensitive, unclassified data that requires safeguarding due to federal regulations. If your organization processes, stores, or transmits CUI, you’ll need to meet the requirements of CMMC, typically at Level 2 of the certification model.
Another common trigger is the flow-down requirement for subcontractors. Prime contractors are responsible for ensuring their subcontractors also comply with the appropriate CMMC level. This means even if you aren’t directly managing a DoD contract, your involvement as a subcontractor could necessitate certification.
Understanding whether your organization deals with CUI is the first step in determining the need for compliance. Identifying this early on can save time and help focus your preparation efforts.
Understanding CMMC Levels
CMMC compliance is structured into three levels, each with distinct requirements tailored to the type of information your organization handles and your role in federal contracts.
- Level 1: Foundational
- Designed for businesses managing only Federal Contract Information (FCI), this level emphasizes basic cyber hygiene practices.
- It requires 15 security controls and an annual self-assessment, making it suitable for organizations with minimal exposure to sensitive data.
- Level 2: Advanced
- This level is critical for organizations handling Controlled Unclassified Information (CUI).
- It builds upon Level 1 with 110 security requirements from NIST SP 800-171 and focuses on protecting sensitive data from cybersecurity threats.
- Compliance involves either a self-assessment or a third-party audit every three years, depending on contract specifications.
- Level 3: Expert
- Reserved for entities managing highly sensitive CUI or critical national security information, this level incorporates advanced controls from NIST SP 800-172.
- It requires assessments by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) and annual affirmations.
The Latest on CMMC Compliance (as of October 2025)
CMMC 2.0 is here. The Department of Defense (DoD) finalized its rulemaking this fall, and CMMC requirements will begin appearing in contracts from November 10, 2025. From that date forward, certification at the required level will be a condition of award for new DoD contracts.
What’s New
The final CMMC Acquisition Rule (48 CFR) was published on September 10, 2025, officially launching the rollout. CMMC will be phased in over four stages:
Phase 1 (Nov 2025–Nov 2026): Level 1 & 2 self-assessments required for contracts involving FCI and CUI.
Phase 2 (Nov 2026–Nov 2027): Third-party Level 2 assessments (C3PAO) begin for contracts handling sensitive CUI.
Phase 3 (Nov 2027–Nov 2028): Level 3 assessments introduced for prioritized CUI.
Phase 4 (Nov 2028 onward): Full implementation across all DoD contracts.
Understanding the Levels
Level 1 (FCI): 15 basic practices; annual self-assessment.
Level 2 (CUI): 110 controls aligned to NIST SP 800-171; mix of self- and third-party assessments.
Level 3 (Prioritized CUI): Adds NIST SP 800-172 controls; DoD-led assessment.
Where Businesses Stand
With enforcement beginning soon, readiness remains low – fewer than 100 Certified Third-Party Assessment Organizations (C3PAOs) are available, and tens of thousands of contractors still need certification. Acting early will be critical to remain eligible for DoD work.
What to Do Now
Identify your required CMMC level.
Conduct a gap analysis against NIST SP 800-171 (Level 2).
Update your System Security Plan (SSP) and POA&M.
Schedule your assessment or self-attestation.
Verify your cloud provider meets FedRAMP Moderate or equivalent standards.
CMMC compliance is now a business imperative – proof that your organization can be trusted to protect sensitive government data.
CMMC Rollout Timeline and Preparing for Compliance
The rollout of CMMC compliance is happening in phases, giving organizations time to align their operations with the new standards. The Department of Defense (DoD) expects CMMC 2.0 to appear in contract solicitations starting in early to mid-2025. Full implementation across all DoD contracts is anticipated by 2028, making it essential for businesses to start preparing now.
To ensure compliance readiness, consider these steps:
- Identify Your Required Level
Determine whether your organization handles Controlled Unclassified Information (CUI) and assess which CMMC level applies to your operations. For most businesses managing CUI, Level 2 will be the target. - Conduct a Gap Analysis
Review your current cybersecurity practices against the requirements of your applicable CMMC level. Identify areas needing improvement, whether they relate to technical safeguards, policies, or employee training. - Implement Necessary Security Measures
Put in place the controls outlined in NIST SP 800-171 for Level 2 or the additional measures required for Level 3. This might involve updating your IT infrastructure, enhancing access controls, or ensuring data encryption is robust. - Train Your Team
Employees play a crucial role in maintaining compliance. Regular training on cybersecurity best practices and awareness of potential threats ensures everyone in your organization contributes to safeguarding sensitive information. - Plan for Assessments
Schedule the required assessments, whether they involve self-assessment, third-party evaluations, or audits by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). Stay proactive to meet deadlines and maintain compliance over time.
As emphasized in the video, early preparation is key. Waiting until the last minute can jeopardize your eligibility for federal contracts and result in costly setbacks. By taking these steps now, you’ll position your organization to meet CMMC requirements confidently and on time.
Ensure CMMC Compliance with Infinity Technologies
CMMC compliance isn’t just a regulatory requirement—it’s a vital step in securing your organization’s role in federal contracts and protecting sensitive data from cyber threats. Whether you’re directly handling Controlled Unclassified Information (CUI) or working as a subcontractor, understanding and meeting the appropriate CMMC level ensures your eligibility and strengthens your cybersecurity posture.
Infinity Technologies specializes in guiding businesses like yours through the complexities of CMMC compliance. From identifying your requirements to implementing security controls and preparing for assessments, our team offers the expertise you need to meet these standards with confidence.
Don’t let compliance challenges hinder your growth. Contact us today to learn how we can support your journey to CMMC certification and ensure your business is ready for success in the federal contracting space.
