How to Determine if Your Business Needs CMMC Certification

The defense contractor landscape shifted drastically over the last few years, and many companies are just finding out they have a problem. CMMC (the Cybersecurity Maturity Model Certification) isn’t just an acronym to ignore; it’s becoming a requirement for those who want any business associated with the Department of Defense. But not every company needing to secure government contracts has to get certified, and many that do have no idea they’re supposed to be.

So how do you know where your business stands?

You Have Controlled Unclassified Information

The first, most significant factor is whether you have what’s known as Controlled Unclassified Information (CUI). CUI is sensitive but not classified government data. This means that while your work is pretty secret in nature, it’s up to you to protect it. CUI might be technical data or specifications, procurement information, personnel data (social security numbers), or documents marked CUI, including emails.

If you’re storing, processing, or transmitting CUI while doing work for the DoD, you absolutely need CMMC certification. The Department of Defense did not want self-attestation anymore; too many contractors said they had good enough cybersecurity practices when they actually didn’t.

Thus, if you’re a company that knows you have such sensitive information, that’s good; you’re one step closer to compliance. But the more common situation is that this information is buried deep within an email attachment or on a shared drive, and the contractor has no idea they’re in possession of such sensitive information until they’re alerted during contract assessment.

Your Place in the Defense Supply Chain

Interestingly enough, you may not even be connected directly to a government contract and still need certification. In defense contracting, there is a commonality of lower-tier subcontractors and vendors. If you’re a subsupplier (meaning you provide materials or services to a prime contractor who submits the information/supplies directly to the government), you might be liable for getting CMMC certified.

The DoD promotes “flow-down requirements.” If you access CUI, you need to comply with the same security requirements as the prime contractor on your contract. If a prime contractor has direct access to CUI but passes down any included components or information or if you have access to their systems holding CUI, you may want to get certified with the same level of compliance as the prime contractor.

Too many small businesses get blindsided by this; they think they’ve been subcontracting for years without an issue, and one day, the prime contractor says, “You need CMMC certification for us to use your services.” It’s not the prime contractor being difficult; they have no choice either.

Small subcontractors are often small businesses without dedicated IT employees or budgets for cybersecurity. They’re machine shops, engineering firms or product developers with a niche; they’ve fallen into defense since their inception, yet if they want to maintain their work, they must have similar security protocols as larger companies.

The Contract Language Says It All

When CMMC is required for your type of contract, it will be clearly stipulated in the Request for Proposal or contract terms. The government will not hide it; they will outline what level of CMMC certification is required; this is typically Level 1 or Level 2 based on how sensitive the information is.

Level 1 is the minimum requirement. This applies to basic cyber hygiene when you’re only dealing with what’s known as Federal Contract Information (FCI) – basically contract-related information that isn’t sensitive unless it’s prescribed to be so. Level 1 requires 17 basic practices and is self-assessed per specific situations.

However, Level 2 is the real doozy that most defense contractors need. If you’re working with CUI in any capacity, you need Level 2 certification as it represents 110 security practices based on NIST SP 800-171 standards, requiring a certified third-party assessment. Thus, you should get Certified CMMC help from an experienced assessor if this is your first go-round with such a requirement for work in defense contracting.

You can assess your current contracts and those for which you’re bidding; if CMMC certification is stated as required, your answer is clear. If it has yet to be mentioned, don’t presume that you’re clear – CMMC compliance is being slowly implemented across the board.

The Work You’re Doing Matters

Not all sectors are getting hit by CMMC requirements immediately. Suppose you’re working in aerospace manufacturing, development or weapons systems, communications technology, or research and development projects for the DoD; you’re likely one of the earlier companies that needs certification if you’re providing such sensitive materials and components.

Those who are helping supply logistics and facilities management and similar components that don’t require taking information probably won’t need Level 1 at all or only require a Level 1 certification as it’s not sensitive data. It comes down to what data you touch for immediate compliance support and what’s stated in your contract or what information you accessed while working with your systems.

Don’t assume what makes sense either; it’s far more complicated than what someone interprets based on the work being performed. For example, a janitorial company might think it doesn’t need compliance unless sensitive data is being handled or stored; however, if said employees have access to buildings where CUI is displayed or walls marking documents as such, there might be different requirements if employees see it or have access to it via daily operations.

You’re Looking for More Defense Contracts

Often, if your current contracts don’t require CMMC yet, you should think about where your work is headed and potential contracting with the DoD moving forward in more sensitive arenas or newer programs. Generalizations surrounding when CMMC is becoming table stakes are developing quickly; some companies are getting kicked out of bid competitions before they even submit proposals because they can’t check off the required box for CMMC certification based on the government qualifier that if you’re not certified yet then we don’t care about your bid at all.

Timing is everything with this; certification doesn’t happen overnight – it happens over months – meaning you need to prepare your system assessment and have necessary practices for any gaps found to comply before bidding for projects. Thus, if you see that perfect project and think that now’s your time, chances are you’ll miss out on the bid window.

What If You’re Not Sure?

Many companies fall into a grey area – maybe you occasionally perform defense-related work but can’t be sure it qualifies as having sensitive information. Maybe you’re a third-tier subcontractor in the flow-down and nobody’s told you anything relevant about what you’ve got going on (or accessible).

The best thing to do is get clarification sooner rather than later – which means reaching out to your contracting officer or prime contractor and inquiring how certain work might require CMMC certification moving forward – even if it seems premature at this junction. Look at contract language justifying what’s required; see what RFPs in your area dictate whether CMMC shows up as a requirement now or guaranteed later on down the line since it’s becoming commonplace in various fields of work.

You can even self-assess yourself against what CMMC requirements suggest before asking someone else to assess; if you’ve accessed any gaps yourself before anyone else finds them, at least you’ve got some time. Some companies are voluntarily certifying earlier since they’ve assessed where standards are headed anyway.

The Bottom Line

CMMC isn’t optional if you’re handling CUI or anticipate trying to provide services for defense contracting that requires compliance-related works later on down the road. Similarly, companies have avoided self-certifying long enough – self-certification will not help anymore as serious audits of companies will implement this practice moving forward – it’s no longer a joke to be played around with by the Department of Defense giving persons/company contractors too much leeway.

If you’re directly contracted by DoD programming and interacting with sensitive materials in any capacity, yes – you need it. If you’re working as a subcontractor within the supply chain for an existing project, there’s a good chance that yes – you need it too unless you’ve confirmed otherwise through a higher power.

If you’re seeking new work opportunities in defense programming – with certifications – that will probably make sense because many new projects will require it anyway moving forward regardless of existence at this time before other regulations trump what’s currently available.

Don’t risk guessing incorrectly – you’ll lose existing contracts or be barred from accessing new opportunities through such noncompliance trends. Assess what’s required now or which level makes sense for your situation and build a robust timeline that makes sense for compliance delivery. The quicker you treat this like a priority, the more likely you’ll continue winning defense contracting work; the longer you ignore it or put it off for later without substantive learning now? You’ll find yourself outside looking in painfully sooner rather than later moving forward through all levels of expectations surrounding industry assessments through time!

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