Achieving CMMC certification is not a one-time achievement. For organizations pursuing continued collaboration with the Department of Defense (DoD), it’s essential to ensure ongoing compliance.
This means that you need to consider what happens after your organization gets CMMC certified and proactively develop the necessary processes to stay compliant. Failing to prepare for continuous compliance increases the risk of falling out of alignment with CMMC, which can expose your organization to vulnerabilities, as well as jeopardize your DoD contracts.
This guide will break down the essentials of retaining your CMMC certification, more specifically:
- Why CMMC compliance must be maintained
- Which continuous compliance requirements you need to meet
- How to stay aligned with CMMC requirements
Why CMMC requires ongoing monitoring
The main purpose of CMMC certification is to offer comprehensive protection to the DoD and its supply chain, including all organizations within the Defense Industrial Base (DIB). Regardless of size, all organizations that handle sensitive data must obtain one of the three CMMC certification levels, with the only exception being suppliers of commercial off-the-shelf (COTS) items.
However, due to the ever-changing security landscape, the practices implemented during the certification process can become outdated, creating a need for continuous oversight and regular updates. Any changes must be done with CMMC requirements in mind, otherwise your organization risks falling out of compliance.
If this happens after your organization has passed the initial certification, you may face consequences based on the severity of the violation, such as:
- Loss of existing contracts
- Ineligibility to bid on future contracts
- Legal consequences
The CMMC framework itself does not prescribe legal action for non-compliance. Instead, enforcement is possible through the False Claims Act (FCA), which the Department of Justice (DoJ) leverages under the Civil Cyber-Fraud Initiative (CCFI). Launched on October 6, 2021, the CCFI enables the DoJ to hold contractors accountable for misrepresenting or failing to meet required cybersecurity standards.
When bidding on DoD contracts, organizations must affirm they meet all requirements for the required CMMC level. If they knowingly misrepresent their cybersecurity compliance status or fail to maintain it, they may face FCA liability under the CCFI.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
Continuous CMMC compliance requirements
The specific practices needed for ongoing CMMC compliance largely depend on your organization’s chosen certification level. For Level 1, organizations must complete an annual self-assessment, while Level 2 and Level 3 require triennial recertification. The table below outlines the requirements:
Your organization must submit annual compliance affirmations independent of certification level. This means you’ll have to conduct security reassessments at least once a year, although continuous monitoring and frequent reviews are preferred as more efficient options, as they help teams avoid last-minute efforts and enable you to pursue DoD opportunities without delays.
The recertification process is similar to the initial assessment, so you will need to complete the entire assessment corresponding to your organization’s certification level:
- Level 1 CMMC certification requires a self-assessment. For Level 2 certification, a self-assessment is also sufficient if the organization handles low-criticality Controlled Unclassified Information (CUI) where a compromise would result in limited operational impact.
- If your organization has a Level 2 certificate and handles more critical CUI—information so vital that its loss could significantly impact national security, public health, the economy, or the environment—it needs to pass an assessment from a CMMC Third-Party Assessor Organization (C3PAO).
- Level 3 requires an assessment by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
To ensure your organization stays CMMC-compliant between certifications, you must have a well-defined approach with clearly outlined security and compliance processes.
4 best practices for maintaining CMMC compliance
Four main practices will ensure your organization remains CMMC-compliant:
- Maintain security and compliance documentation
- Set up continuous monitoring
- Conduct regular security reviews
- Automate as much as possible
We’ll discuss the most significant aspects of each below.
1. Maintain security and compliance documentation
Keeping extensive documentation of implemented security practices is a key aspect of managing CMMC compliance. By creating, reviewing, and maintaining thorough evidence of the effective implementation of each in-scope CMMC practice, organizations are better prepared for reviews and audits.
For higher-level CMMC certificates, this is even more important. To achieve Level 2 or 3 certification, you need to prepare and keep a detailed System Security Plan (SSP), which outlines implemented practices and processes and how they align with CMMC requirements.
Other critical documents that you will want to collect as part of compliance efforts include:
- Access control policies and procedures
- Accountability policies and procedures
- System monitoring records
- Continuous monitoring strategies
- Risk management policies and procedures
- Incident response plans
Without centralization, gathering this documentation will require compliance and risk teams to go through disparate, siloed systems, slowing down compliance workflows. By creating a central documentation hub, you can ensure the documentation is readily available in one place, simplifying the collection process.
Streamlining evidence collection through centralization or automation helps your organization save time and resources by ensuring that all required documentation is readily available. It also reduces the risk of human error or missing documentation, which can slow down assessments.
{{cta_withimage22="/cta-blocks"}} | The audit ready checklist
2. Set up continuous monitoring
“
An effective strategy for continuously monitoring and reevaluating security controls is to set up processes to test your CMMC practices regularly. This ensures they operate effectively, securing ongoing alignment with CMMC requirements.”
Once you’ve implemented CMMC processes, you should set up ongoing monitoring to ensure they are working effectively.
Without continuous monitoring, processes can become subject to issues and disruptions, which, when left undetected, can lead to vulnerabilities, risking non-compliance.
Manually monitoring processes presents compliance and security teams with several significant challenges. This point-in-time information can quickly become outdated, making it harder to identify areas that require more attention. It also adds extensive work, which can lead to burnout and inefficiencies within smaller compliance teams.
A more effective way to monitor processes is to leverage software tools that gather real-time information, providing compliance teams with up-to-date reports that allow them to quickly identify and address any deviations.
3. Conduct regular security reviews
Waiting for the annual CMMC recertification and affirmation deadlines to perform a security review might lead to haphazard workflows and inaccuracies. Instead, you should conduct regular security reviews to ensure that compliance and security teams have up-to-date insight on how practices align with CMMC requirements.
Although you should regularly test every component of your organization’s security posture, these key CMMC compliance aspects require more frequent checks:
- Access to systems: Conduct regular checks to recognize and remove access privileges from unauthorized and inactive accounts. Grant access according to the principle of least privilege, meaning accounts can only access the minimum amount of information necessary for their roles.
- Relevant security policies: Ensure that all security policies are up-to-date and meet the latest CMMC requirements. Organize regular awareness campaigns and security training to guarantee all organization members understand security practices.
- Incident responses and treatment practices: Regularly test your incident response plan to verify it covers a variety of scenarios such as data breaches or denial of service attacks. Clarify and review the roles of all team members in charge of incident response to ensure they can respond quickly and effectively.
Documenting the review process is also extremely important. Having transparent records of security reviews provides clear evidence of ongoing CMMC compliance efforts to assessors, helping streamline affirmations and recertifications.
4. Automate as much as possible
Inefficient compliance workflows, such as collecting documentation manually, take away valuable time from stakeholders, disrupting day-to-day activities. Inefficiencies can also create bottlenecks, which require additional resources to be resolved and can result in missed deadlines and slowed-down response times.
To avoid these recurring issues and reduce the burden on your teams, leverage automation wherever possible. By automating repetitive tasks such as evidence collection, compliance checks, and risk control, you can minimize manual work, freeing up team resources while maximizing workflow efficiency.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
Stay CMMC compliant with Vanta
Vanta is a trust management platform that helps your organization obtain a CMMC certificate and ensure ongoing compliance. It provides guidance and resources to make the process more efficient and automates up to 50 percent of related workflows.
The platform offers a dedicated CMMC solution equipped with various features that will help you streamline compliance workflows, including:
- Out-of-the-box support for all CMMC certification levels
- Automated evidence collection supported by 375+ integrations
- Automated gap assessments
- Centralized tracking and continuous monitoring of CMMC requirements
- Pre-mapped security controls aligned to NIST SP 800-171 and NIST SP 800-172
- Prescriptive guidance across controls, policies, and documents that help reduce uncertainty
Vanta also partners with reputable C3PAOs necessary for Level 2 or 3 certificate assessments. Browse Vanta’s partner network to find a C3PAO who can assist your organization with every step of CMMC compliance, from achieving certification to maintaining it.
Schedule a custom demo to see how Vanta’s CMMC solution supports ongoing compliance efforts for your team.
{{cta_simple33="/cta-blocks"}} | CMMC product page
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
How to maintain CMMC compliance
Looking to streamline the work for CMMC?
Achieving CMMC certification is not a one-time achievement. For organizations pursuing continued collaboration with the Department of Defense (DoD), it’s essential to ensure ongoing compliance.
This means that you need to consider what happens after your organization gets CMMC certified and proactively develop the necessary processes to stay compliant. Failing to prepare for continuous compliance increases the risk of falling out of alignment with CMMC, which can expose your organization to vulnerabilities, as well as jeopardize your DoD contracts.
This guide will break down the essentials of retaining your CMMC certification, more specifically:
- Why CMMC compliance must be maintained
- Which continuous compliance requirements you need to meet
- How to stay aligned with CMMC requirements
Why CMMC requires ongoing monitoring
The main purpose of CMMC certification is to offer comprehensive protection to the DoD and its supply chain, including all organizations within the Defense Industrial Base (DIB). Regardless of size, all organizations that handle sensitive data must obtain one of the three CMMC certification levels, with the only exception being suppliers of commercial off-the-shelf (COTS) items.
However, due to the ever-changing security landscape, the practices implemented during the certification process can become outdated, creating a need for continuous oversight and regular updates. Any changes must be done with CMMC requirements in mind, otherwise your organization risks falling out of compliance.
If this happens after your organization has passed the initial certification, you may face consequences based on the severity of the violation, such as:
- Loss of existing contracts
- Ineligibility to bid on future contracts
- Legal consequences
The CMMC framework itself does not prescribe legal action for non-compliance. Instead, enforcement is possible through the False Claims Act (FCA), which the Department of Justice (DoJ) leverages under the Civil Cyber-Fraud Initiative (CCFI). Launched on October 6, 2021, the CCFI enables the DoJ to hold contractors accountable for misrepresenting or failing to meet required cybersecurity standards.
When bidding on DoD contracts, organizations must affirm they meet all requirements for the required CMMC level. If they knowingly misrepresent their cybersecurity compliance status or fail to maintain it, they may face FCA liability under the CCFI.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
Continuous CMMC compliance requirements
The specific practices needed for ongoing CMMC compliance largely depend on your organization’s chosen certification level. For Level 1, organizations must complete an annual self-assessment, while Level 2 and Level 3 require triennial recertification. The table below outlines the requirements:
Your organization must submit annual compliance affirmations independent of certification level. This means you’ll have to conduct security reassessments at least once a year, although continuous monitoring and frequent reviews are preferred as more efficient options, as they help teams avoid last-minute efforts and enable you to pursue DoD opportunities without delays.
The recertification process is similar to the initial assessment, so you will need to complete the entire assessment corresponding to your organization’s certification level:
- Level 1 CMMC certification requires a self-assessment. For Level 2 certification, a self-assessment is also sufficient if the organization handles low-criticality Controlled Unclassified Information (CUI) where a compromise would result in limited operational impact.
- If your organization has a Level 2 certificate and handles more critical CUI—information so vital that its loss could significantly impact national security, public health, the economy, or the environment—it needs to pass an assessment from a CMMC Third-Party Assessor Organization (C3PAO).
- Level 3 requires an assessment by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
To ensure your organization stays CMMC-compliant between certifications, you must have a well-defined approach with clearly outlined security and compliance processes.
4 best practices for maintaining CMMC compliance
Four main practices will ensure your organization remains CMMC-compliant:
- Maintain security and compliance documentation
- Set up continuous monitoring
- Conduct regular security reviews
- Automate as much as possible
We’ll discuss the most significant aspects of each below.
1. Maintain security and compliance documentation
Keeping extensive documentation of implemented security practices is a key aspect of managing CMMC compliance. By creating, reviewing, and maintaining thorough evidence of the effective implementation of each in-scope CMMC practice, organizations are better prepared for reviews and audits.
For higher-level CMMC certificates, this is even more important. To achieve Level 2 or 3 certification, you need to prepare and keep a detailed System Security Plan (SSP), which outlines implemented practices and processes and how they align with CMMC requirements.
Other critical documents that you will want to collect as part of compliance efforts include:
- Access control policies and procedures
- Accountability policies and procedures
- System monitoring records
- Continuous monitoring strategies
- Risk management policies and procedures
- Incident response plans
Without centralization, gathering this documentation will require compliance and risk teams to go through disparate, siloed systems, slowing down compliance workflows. By creating a central documentation hub, you can ensure the documentation is readily available in one place, simplifying the collection process.
Streamlining evidence collection through centralization or automation helps your organization save time and resources by ensuring that all required documentation is readily available. It also reduces the risk of human error or missing documentation, which can slow down assessments.
{{cta_withimage22="/cta-blocks"}} | The audit ready checklist
2. Set up continuous monitoring
“
An effective strategy for continuously monitoring and reevaluating security controls is to set up processes to test your CMMC practices regularly. This ensures they operate effectively, securing ongoing alignment with CMMC requirements.”
Once you’ve implemented CMMC processes, you should set up ongoing monitoring to ensure they are working effectively.
Without continuous monitoring, processes can become subject to issues and disruptions, which, when left undetected, can lead to vulnerabilities, risking non-compliance.
Manually monitoring processes presents compliance and security teams with several significant challenges. This point-in-time information can quickly become outdated, making it harder to identify areas that require more attention. It also adds extensive work, which can lead to burnout and inefficiencies within smaller compliance teams.
A more effective way to monitor processes is to leverage software tools that gather real-time information, providing compliance teams with up-to-date reports that allow them to quickly identify and address any deviations.
3. Conduct regular security reviews
Waiting for the annual CMMC recertification and affirmation deadlines to perform a security review might lead to haphazard workflows and inaccuracies. Instead, you should conduct regular security reviews to ensure that compliance and security teams have up-to-date insight on how practices align with CMMC requirements.
Although you should regularly test every component of your organization’s security posture, these key CMMC compliance aspects require more frequent checks:
- Access to systems: Conduct regular checks to recognize and remove access privileges from unauthorized and inactive accounts. Grant access according to the principle of least privilege, meaning accounts can only access the minimum amount of information necessary for their roles.
- Relevant security policies: Ensure that all security policies are up-to-date and meet the latest CMMC requirements. Organize regular awareness campaigns and security training to guarantee all organization members understand security practices.
- Incident responses and treatment practices: Regularly test your incident response plan to verify it covers a variety of scenarios such as data breaches or denial of service attacks. Clarify and review the roles of all team members in charge of incident response to ensure they can respond quickly and effectively.
Documenting the review process is also extremely important. Having transparent records of security reviews provides clear evidence of ongoing CMMC compliance efforts to assessors, helping streamline affirmations and recertifications.
4. Automate as much as possible
Inefficient compliance workflows, such as collecting documentation manually, take away valuable time from stakeholders, disrupting day-to-day activities. Inefficiencies can also create bottlenecks, which require additional resources to be resolved and can result in missed deadlines and slowed-down response times.
To avoid these recurring issues and reduce the burden on your teams, leverage automation wherever possible. By automating repetitive tasks such as evidence collection, compliance checks, and risk control, you can minimize manual work, freeing up team resources while maximizing workflow efficiency.
{{cta_withimage27="/cta-blocks"}} | CMMC compliance checklist
Stay CMMC compliant with Vanta
Vanta is a trust management platform that helps your organization obtain a CMMC certificate and ensure ongoing compliance. It provides guidance and resources to make the process more efficient and automates up to 50 percent of related workflows.
The platform offers a dedicated CMMC solution equipped with various features that will help you streamline compliance workflows, including:
- Out-of-the-box support for all CMMC certification levels
- Automated evidence collection supported by 375+ integrations
- Automated gap assessments
- Centralized tracking and continuous monitoring of CMMC requirements
- Pre-mapped security controls aligned to NIST SP 800-171 and NIST SP 800-172
- Prescriptive guidance across controls, policies, and documents that help reduce uncertainty
Vanta also partners with reputable C3PAOs necessary for Level 2 or 3 certificate assessments. Browse Vanta’s partner network to find a C3PAO who can assist your organization with every step of CMMC compliance, from achieving certification to maintaining it.
Schedule a custom demo to see how Vanta’s CMMC solution supports ongoing compliance efforts for your team.
{{cta_simple33="/cta-blocks"}} | CMMC product page
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
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CMMC requirements
CMMC certification process
CMMC levels
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