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Phase 1: Now Active

Level 1 & Level 2 Self-Assessments
Effective December 16, 2024

If you’re bidding on new DoD contracts today, you’re already required to complete a self-assessment. We’ll help you validate your controls, close gaps, and organize your documentation so you’re ready when it counts.

Phase 2: Certification Required

Level 2 C3PAO Assessments

Effective December 16, 2025

Third-party certification will become mandatory for Level 2. As an authorized C3PAO, S3 Security can deliver your official assessment—or support your preparation through mock audits and targeted remediation support.

Phase 3: Advanced Compliance

Level 3 and NIST SP 800-172

Effective December 16, 2026

The most advanced level of CMMC introduces 24 additional controls for organizations handling the most sensitive defense information. We can help you determine if this applies to you and guide you through preparation for DIBCAC review.

At this point, the rollout will be complete with all CMMC requirements incorporated into any new solicitations.

Not sure where to start? Let’s talk. Our team can help you understand your requirements and plan next steps.

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How Does This Impact Subcontractors & ESPs?

The final rule requires contractors to document the role of External Service Providers (ESPs) in their System Security Plan (SSP), especially if those services help meet CMMC requirements. These providers will also be subject to control assessments. Additional guidelines apply to cloud service providers (CSPs), which must meet FedRAMP Moderate or equivalent requirements.

Can We Limit Our Commitment to CMMC?

Yes. Many companies choose to narrow the scope of their CMMC environment by segmenting systems or isolating their DoD-related infrastructure. One effective strategy is establishing a CUI enclave: a defined environment where Controlled Unclassified Information (CUI) is stored, processed, and transmitted. However, this approach only works if you have a clear understanding of your data flows and where CUI resides across your environment.

What Other Factors Should We Plan For?

Technical debt and outdated infrastructure can complicate compliance, particularly for smaller organizations. A CMMC gap assessment can help prioritize where to invest for the greatest impact. On the business side, executive buy-in is essential, since compliance often requires reallocating time, budget, and internal resources. Leadership support is critical to long-term success.

How Will Deficiencies Be Addressed?

Plans of Actions and Milestones (POAMs) are allowed for some controls, giving organizations time-bound opportunities to resolve issues. However, POAMs are not allowed for Level 1 controls and must lead to full control implementation, not just a reduction in risk. S3 Security can help you develop a remediation plan that’s practical, prioritized, and audit-ready.

How Can We Ensure Continuing Compliance?

CMMC requires ongoing commitment, not just a one-time assessment. Organizations must designate a senior official to regularly attest that all applicable requirements are implemented and maintained. S3 Security can help you establish sustainable processes that support long-term compliance and simplify ongoing attestations.

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EXPERIENCE & EXPERTISE YOU CAN COUNT ON

With over 25 years of industry leadership, our assessors and engineers possess deep technical knowledge and proven success across regulated environments. We maintain active certifications with key federal and industry organizations, and we’re proud to be both a Registered Practitioner Organizations (RPO) and an authorized Third-Party Assessment Organization (C3PAO).

A list of certification logos including NIST, PCISSC, CompTIA, Offensive Security, OWASP, SANS, ISACA, ISO, ISC, CEH, CIS and Cyber AB

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