The three CMMC levels
| Level | For | Requirements | Assessment |
|---|---|---|---|
| 1 | Federal Contract Information (FCI) | 15 requirements from FAR 52.204-21 | Annual self-assessment |
| 2 | Controlled Unclassified Information (CUI) | 110 requirements of NIST SP 800-171 Rev 2 | Self-assessment or certification by a C3PAO, as the contract specifies, every three years |
| 3 | The most sensitive CUI programs | Level 2 plus 24 requirements from NIST SP 800-172 | Assessment by DoD (DIBCAC) |
Timeline
- The CMMC Program rule (32 CFR Part 170) took effect on 16 December 2024.
- The DFARS rule that puts CMMC into contracts (clause 252.204-7021) took effect on 10 November 2025, with requirements phased into new solicitations over the following years.
- Separately, contractors handling CUI must post their NIST SP 800-171 assessment score in SPRS (DFARS 252.204-7019).
Plans of action (POA&Ms)
A Level 2 assessment can pass with some requirements still open on a plan of action, but only certain requirements qualify, a minimum score is needed, and open items must be closed within 180 days (32 CFR 170.21).
What it costs
In the final rule, DoD estimated the cost of supporting a Level 2 certification assessment at about $101,752 for a small entity and $112,345 for other entities, and a Level 1 self-assessment at about $5,977 or $4,042 a year. Those estimates assume the controls are already in place. Getting there (remediation) is usually the bigger cost, and the calculator above adds our estimate for it by organisation size.
Where to start
- Check your contracts for FCI, CUI and the CMMC clause; that decides your level.
- Scope the systems that store, process or transmit CUI, and shrink that scope where you can.
- Run a gap assessment against NIST SP 800-171 and write your System Security Plan.
- Fix the gaps in order of risk, then score yourself honestly in SPRS.
We run the gap assessment and the technical remediation. See vCISO services and VAPT.
Sources
- CMMC Program final rule, 32 CFR Part 170 (Federal Register, 15 October 2024)
- 32 CFR 170.14 and 32 CFR 170.21 (eCFR)
- DFARS CMMC acquisition rule (Federal Register, 10 September 2025)
- DFARS 252.204-7019 (eCFR)
Facts checked against the sources above on 22 October 2026. General information, not legal advice.
