CMMC Compliance: Levels for DoD Contractors

CMMC Compliance Levels Overview

CMMC Compliance, or Cybersecurity Maturity Model Certification, is a framework designed to assess and enhance the cybersecurity posture of companies working with the U.S. Department of Defense (DoD). It establishes structured guidelines to improve cybersecurity across the Defense Industrial Base (DIB) sector. Achieving CMMC Compliance ensures that appropriate security practices and processes are in place to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the DIB network.

CMMC Compliance Levels Overview

The CMMC Compliance framework consists of five certification levels, each demonstrating a company’s cybersecurity maturity and reliability. These levels are cumulative, meaning organizations must meet all lower-level requirements before advancing, ensuring they can effectively safeguard sensitive government information.

To achieve CMMC Compliance, contractors must meet standards across 17 domains, 43 capabilities, 171 practices, and 5 processes. If a contractor does not meet the required standards for both practices and processes, they will be certified at the lowest level achieved.

Not all contractors need to attain Level five of CMMC Compliance; the required level depends on the sensitivity of the DoD information they handle and the cyber threats associated with it.

CMMC Compliance Levels Description

Level 1 – Basic Cyber Hygiene

  • Processes: Performed
  • Practices: Basic cyber hygiene

Level 1 CMMC Compliance focuses on protecting Federal Contract Information (FCI) and includes only the fundamental cybersecurity practices required by 48 CFR 52.204-21 (“Basic Safeguarding of Covered Contractor Information Systems”). At this level, organizations must implement basic security measures to ensure compliance but are not required to have documented processes.

Level 2 – Intermediate Cyber Hygiene

  • Processes: Documented
  • Practices: Intermediate cyber hygiene

Level 2 CMMC Compliance requires contractors to document their cybersecurity practices and policies to ensure consistent and repeatable implementation. This level serves as a bridge between Level 1 and Level 3 CMMC Compliance, incorporating a subset of the security requirements from NIST SP 800-171, along with additional practices from other standards and references.

Level 3 – Good Cyber Hygiene

  • Processes: Managed
  • Practices: Good cyber hygiene

Level 3 CMMC Compliance requires organizations to establish, maintain, and resource a documented cybersecurity plan that demonstrates the management of security practices. This plan should include details on missions, goals, project plans, resource allocation, required training, and stakeholder involvement to ensure consistent cybersecurity implementation.

Level 3 focuses on protecting Controlled Unclassified Information (CUI) and fully incorporates all security requirements from NIST SP 800-171, along with additional practices from other standards to mitigate cyber threats.

Additionally, DFARS clause 252.204-7012 (“Safeguarding of Covered Defense Information and Cyber Incident Reporting”) applies at this level, reinforcing security requirements for Defense Industrial Base (DIB) contractors.

Level 4 – Proactive

  • Processes: Reviewed
  • Practices: Proactive

Level 4 CMMC Compliance requires organizations to review and measure their cybersecurity practices for effectiveness. At this level, companies must also be capable of taking corrective action when necessary and regularly informing higher-level management about security status or issues.

Level 4 focuses on protecting Controlled Unclassified Information (CUI) from Advanced Persistent Threats (APTs). It incorporates a subset of the enhanced security requirements from Draft NIST SP 800-171B, along with additional cybersecurity best practices.

These advanced security measures improve an organization’s ability to detect, respond to, and adapt against evolving tactics, techniques, and procedures (TTPs) used by APTs.

Level 5 – Advanced/Progressive

  • Processes: Optimizing
  • Practices: Advanced/proactive

Level 5 CMMC Compliance requires organizations to standardize and optimize cybersecurity processes across their entire operation. At this level, companies must ensure continuous improvement and refinement of their security practices to effectively counter evolving threats.

Level 5 focuses on protecting Controlled Unclassified Information (CUI) from Advanced Persistent Threats (APTs). The additional security practices enhance the depth and sophistication of an organization’s cybersecurity capabilities, ensuring a proactive and adaptive defense against advanced cyber threats.

Enhancing DoD Contractor Security: From DFARS to CMMC Compliance

Before the introduction of CMMC Compliance, DFARS clause 252.204-7012 required DoD contractors to implement, monitor, and certify the security of their technology systems. This included safeguarding sensitive Department of Defense (DoD) information stored or transmitted within their infrastructure. While contractors are still responsible for implementing key cybersecurity capabilities, CMMC Compliance enhances security by introducing third-party assessments to verify adherence to mandatory cybersecurity practices, procedures, and capabilities.

By requiring CMMC certification, the Department of Defense strengthens the cybersecurity posture of its supply chain. This framework ensures that contractors can effectively protect sensitive information from evolving cyber threats. Additionally, CMMC Compliance helps standardize cybersecurity requirements across the Defense Industrial Base (DIB), creating a consistent level of security readiness among all DoD contractors.

Next Steps for Contractors CMMC Compliance

To achieve CMMC Compliance, contractors must familiarize themselves with the framework’s technical requirements and prepare for both certification and long-term cybersecurity resilience. This includes evaluating existing practices, procedures, and potential gaps to ensure full compliance while proactively addressing vulnerabilities.

Sepio provides valuable assistance to DoD contractors navigating the complexities of CMMC Compliance. Our platform ensures comprehensive coverage across all CMMC levels, including the stringent requirements of Level 5.

As the leader in Rogue Device Mitigation (RDM), Sepio’s Asset Risk Management (ARM) platform delivers unmatched visibility into all connected peripherals, identifying hidden hardware threats across network and USB interfaces.

Sepio's Discovered Assets
Sepio’s Discovered Assets

Sepio is the only company in the world to provide physical-layer visibility, using device fingerprinting to detect and automatically block malicious hardware attacks. Schedule a demo today to learn how Sepio can help your organization achieve and maintain CMMC Compliance while strengthening overall cybersecurity defenses.

Know More About Cybersecurity Compliance

October 5th, 2020