How to Perform a CMMC 2.0 Gap Analysis: Complete Guide

Organizations working with the Department of Defense (DoD) face mounting pressure to achieve Cybersecurity Maturity Model Certification (CMMC) 2.0 compliance. With billions in defense contracts at stake and implementation timelines accelerating, conducting a thorough gap analysis has become critical for maintaining competitive positioning and avoiding costly compliance failures.

This comprehensive guide walks you through the essential steps to perform an effective CMMC 2.0 gap analysis, providing actionable frameworks, best practices, and risk mitigation strategies to ensure your organization meets certification requirements while protecting sensitive defense information.

Executive Summary

Main Idea: A CMMC 2.0 gap analysis systematically evaluates your organization’s current cybersecurity posture against required CMMC controls to identify deficiencies, prioritize remediation efforts, and create a roadmap for certification compliance.

Why You Should Care: Without proper gap analysis, organizations risk losing DoD contracts worth billions annually, face potential data breaches exposing Controlled Unclassified Information (CUI), and may invest resources inefficiently in non-critical security measures while leaving critical vulnerabilities unaddressed.

Key Takeaways

1. The CMMC 2.0 level you choose determines your entire gap analysis strategy. Your required certification level (Level 1, 2, or 3) fundamentally changes the scope, timeline, and cost of your gap analysis, from 17 basic controls to 134 advanced requirements with dramatically different resource needs.
2. Systematic 9-step process ensures comprehensive gap analysis coverage. Following a structured approach from level determination through implementation preparation prevents critical oversights and ensures all 110+ security controls are properly evaluated against current capabilities and documented effectively.
3. Level 2 gap analysis requires 4-8 weeks and $100k-$500k investment. Advanced certification demands comprehensive assessment of NIST SP 800-171 controls, extensive documentation review, and significant resource allocation that scales based on organizational complexity and current security posture.
4. Documentation gaps cause more certification failures than technical deficiencies. Many organizations have adequate security measures but lack proper policies, procedures, and evidence trails required by CMMC assessors, making documentation review the most critical gap analysis component.
5. Early preparation and expert engagement maximize CMMC compliance success rates. Organizations that begin gap analysis 12-18 months before contract requirements and engage third-party expertise achieve certification faster while avoiding costly last-minute remediation efforts and contract losses.

CMMC 2.0 Framework Essentials for Gap Analysis Success

The CMMC 2.0 framework represents a significant evolution in DoD cybersecurity requirements, streamlining the original five-level model into a more practical three-level approach. This simplified structure focuses on protecting Controlled Unclassified Information (CUI) while reducing compliance burden for smaller defense contractors.

Identify Level Requirements That Determine Your Gap Analysis Scope

CMMC 2.0 operates on three primary certification levels, each targeting different types of defense contractors and information sensitivity levels. CMMC Level 1, known as “Foundational,” requires implementation of 17 basic cybersecurity practices derived from FAR 52.204-21. CMMC Level 2, designated as “Advanced,” mandates 110 security controls based on NIST 800-171, representing a comprehensive cybersecurity program. CMMC Level 3 (Expert), adds 24 enhanced requirements from NIST SP 800-172 for the most sensitive national security information.

The level determination depends entirely on whether your organization handles CUI and the criticality of that information. Companies that only process Federal Contract Information (FCI) typically require Level 1 certification, while those handling CUI must achieve Level 2 compliance, and organizations supporting the most sensitive missions require Level 3.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

Map the 14 Control Families Your Gap Analysis Must Address

CMMC 2.0 organizes security requirements into 14 distinct control families, each addressing specific cybersecurity domains. These families include Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification and Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Recovery, Risk Management, System and Communications Protection, and System and Information Integrity.

Each control family contains multiple individual controls with specific implementation requirements, assessment objectives, and evidence expectations. Understanding these relationships is crucial for effective gap analysis planning.

Each of these 14 control families have specific requirements that defense contractors must meet in order to demonstrate CMMC compliance. We encourage you to explore each domain in detail, understand their requirements, and consider our best practice strategies for compliance: Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification & Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Risk Assessment, Security Assessment, System & Communications Protection, and System and Information Integrity.

CMMC 2.0 Gap Analysis Requirements by Certification Level

The gap analysis process varies significantly depending on your required CMMC 2.0 certification level. Understanding these differences is crucial for proper resource planning, timeline development, and budget allocation for your compliance efforts.

How to Perform a CMMC 2.0 Gap Analysis: 9-Step Process

Follow this comprehensive step-by-step process to conduct an effective CMMC 2.0 gap analysis that identifies all compliance deficiencies and creates a clear path to certification.

1. Determine Your CMMC Level Requirements

Start by identifying whether your organization handles Federal Contract Information (FCI) only or Controlled Unclassified Information (CUI). Organizations processing only FCI typically require CMMC Level 1 certification with 17 basic security practices, while those handling CUI must achieve CMMC Level 2 compliance with 110 comprehensive security controls. CMMC Level 3 applies to the most sensitive national security information. Review your current and planned DoD contracts to confirm the required certification level, as this determination drives your entire gap analysis scope.

2. Assemble Your Gap Analysis Team

Build a cross-functional team including IT security professionals, compliance specialists, legal counsel familiar with government contracting, and business leaders who understand operational requirements and budget constraints. Consider engaging external CMMC consultants or registered practitioner organizations (RPOs) to provide specialized expertise and objective assessment capabilities from multiple implementation experiences.

3. Define Scope and Boundaries

Create a comprehensive inventory of all systems, networks, and processes that handle FCI or CUI, as these fall under CMMC requirements. Develop detailed network diagrams showing data flows, system interconnections, and security boundaries. Document your organization’s current cybersecurity investments, including existing tools, policies, procedures, and training programs to establish your assessment baseline.

4. Inventory All Systems and Assets

Catalog all IT assets within your CMMC scope, including servers, workstations, mobile devices, network equipment, software applications, and cloud services. Classify each asset based on its role in processing, storing, or transmitting FCI or CUI. Document current asset management practices, including how you track hardware and software inventory, manage system configurations, and control asset lifecycle processes.

5. Assess Current Security Controls

Systematically evaluate each applicable CMMC control against your current implementation. For Level 2 organizations, assess all 110 security controls across the 14 control families. Create a standardized assessment framework that rates each control as Fully Implemented, Partially Implemented, Planned, or Not Implemented. Document the specific technologies, processes, and procedures currently addressing each control requirement.

6. Document Findings and Gaps

Create a detailed gap analysis matrix that maps each CMMC control to your current implementation status. For each identified gap, document the specific deficiency, potential impact on certification, and estimated effort required for remediation. Review all existing cybersecurity policies, procedures, and work instructions to determine alignment with CMMC requirements, as many organizations have effective security practices but lack formal documentation required for certification.

7. Prioritize Remediation Efforts

Conduct a thorough risk assessment that considers both the likelihood of certification failure and the potential business impact of each identified deficiency. Develop a systematic approach to prioritizing gaps based on compliance risk, implementation complexity, cost, and business impact. Consider quick wins that can demonstrate progress while planning for larger infrastructure investments that may require multiple budget cycles.

8. Create Remediation Roadmap

Develop comprehensive budget estimates that include technology costs, professional services, internal labor, and ongoing operational expenses. Create realistic timelines that account for procurement cycles, implementation complexity, and organizational change management requirements. Establish clear milestones and success criteria for each phase of your remediation effort, with regular progress reviews to maintain momentum.

9. Execute Implementation and Prepare for Assessment

Begin implementing your remediation roadmap by addressing high-priority gaps first while building supporting documentation and evidence collection processes. Engage with a CMMC Third Party Assessment Organization (C3PAO) early to understand their specific assessment requirements and evidence expectations. Conduct internal readiness assessments throughout implementation to validate control effectiveness and documentation completeness before your official CMMC assessment.

Gap Analysis Preparation: Foundation for CMMC 2.0 Success

Successful gap analysis requires thorough preparation, including stakeholder alignment, resource allocation, and scope definition. The preparation phase often determines the quality and usefulness of your final assessment results.

Assemble Your Team for Effective CMMC 2.0 Analysis

Building an effective gap analysis team requires representation from multiple organizational functions. Your core team should include IT security professionals, compliance specialists, legal counsel familiar with government contracting, and business leaders who understand operational requirements and budget constraints.

Consider engaging external CMMC consultants or registered practitioner organizations (RPOs) to provide specialized expertise and objective assessment capabilities. These professionals bring experience from multiple CMMC implementations and can identify common pitfalls that internal teams might overlook.

Define Scope Parameters That Prevent Analysis Overruns

Scope definition directly impacts both the cost and effectiveness of your gap analysis. Begin by cataloging all systems, networks, and processes that handle FCI or CUI, as these will fall under CMMC requirements. Create detailed network diagrams showing data flows, system interconnections, and security boundaries.

Document your organization’s current cybersecurity investments, including existing tools, policies, procedures, and training programs. This baseline inventory prevents duplicate efforts and identifies areas where current investments can support CMMC compliance.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

Current State Assessment Framework for CMMC 2.0 Compliance

The current state assessment forms the foundation of your gap analysis, requiring systematic evaluation of existing cybersecurity controls against CMMC requirements. This phase demands meticulous documentation and objective evaluation to ensure accurate results.

Asset Inventory Methods That Capture CMMC 2.0 Requirements

Begin your assessment by creating a comprehensive inventory of all IT assets within your CMMC scope. This includes servers, workstations, mobile devices, network equipment, software applications, and cloud services. Each asset should be classified based on its role in processing, storing, or transmitting FCI or CUI.

Document current asset management practices, including how you track hardware and software inventory, manage system configurations, and control asset lifecycle processes. Many organizations discover significant gaps in basic asset visibility during this phase.

Security Control Evaluation Techniques for Accurate Gap Analysis

Systematically evaluate each applicable CMMC control against your current implementation. For Level 2 organizations, this means assessing all 110 security controls across the 14 control families. Create a standardized assessment framework that rates each control as Fully Implemented, Partially Implemented, Planned, or Not Implemented.

Document the specific technologies, processes, and procedures currently addressing each control requirement. Include details about automation levels, manual processes, and any compensating controls that might partially satisfy requirements.

Documentation Standards That Pass CMMC 2.0 Assessments

CMMC assessments heavily emphasize documentation quality and completeness. Review all existing cybersecurity policies, procedures, and work instructions to determine alignment with CMMC requirements. Many organizations have effective security practices but lack the formal documentation required for certification.

Evaluate your current documentation standards, including version control, approval processes, and regular review cycles. Identify gaps where policies exist but lack supporting procedures, or where procedures exist without proper management oversight and approval.

CMMC 2.0 Gap Analysis Methods That Reveal Critical Deficiencies

Gap identification requires systematic comparison between your current state assessment results and CMMC requirements. This analysis should produce actionable insights that guide your remediation planning and investment decisions.

Control-by-Control Analysis Techniques for Complete Coverage

Create a detailed gap analysis matrix that maps each CMMC control to your current implementation status. For each identified gap, document the specific deficiency, potential impact on certification, and estimated effort required for remediation. This granular analysis ensures no requirements are overlooked during implementation planning.

Pay particular attention to controls that require integration across multiple systems or business processes. These often represent the most complex and time-consuming remediation efforts, requiring early identification and planning.

Risk Assessment Framework for CMMC 2.0 Gap Prioritization

Not all gaps carry equal risk or remediation complexity. Conduct a thorough risk assessment that considers both the likelihood of certification failure and the potential business impact of each identified deficiency. Factor in the cost and timeline for remediation when prioritizing your gap closure efforts.

Consider both direct compliance risks and broader cybersecurity risks that could affect your organization’s security posture. Some gaps may represent minimal CMMC compliance risk but significant operational security vulnerabilities.

Technology Infrastructure Gaps That Block CMMC 2.0 Certification

Many organizations discover that their current technology infrastructure cannot support CMMC requirements without significant upgrades or replacements. Common technology gaps include inadequate logging and monitoring capabilities, insufficient network segmentation, outdated authentication systems, and inadequate backup and recovery solutions.

Evaluate whether current systems can be upgraded to meet CMMC requirements or whether replacement solutions are necessary. Consider the total cost of ownership, including licensing, implementation, training, and ongoing maintenance costs.

Ready for CMMC compliance? Less than half of Defense Industrial Base (DIB) contractors are prepared for CMMC 2.0 Level 2 certification, according to our joint report with Coalfire, State of CMMC 2.0 Preparedness Report. Learn what’s driving the compliance gaps and challenges in this comprehensive survey presenting insights from over 200 defense contractors.

CMMC 2.0 Gap Analysis Best Practices That Guarantee Accuracy

Implementing proven best practices significantly improves the accuracy and usefulness of your CMMC 2.0 gap analysis while reducing the time and resources required for completion.

Deploy Automated Assessment Tools for Faster CMMC 2.0 Analysis

Modern cybersecurity assessment tools can significantly accelerate your gap analysis process while improving accuracy and consistency. These tools can automatically inventory assets, assess security configurations, and map findings to specific CMMC controls. However, automated tools should supplement, not replace, human expertise and judgment.

Select tools that provide CMMC-specific reporting capabilities and can integrate with your existing security infrastructure. Ensure any tools you choose can export results in formats suitable for documentation and remediation planning.

Engage Third-Party Experts for Objective CMMC 2.0 Validation

External CMMC consultants and assessment professionals like registered provider organizations (RPOs) and certified third-party assessor organizations (C3PAOs) bring valuable experience from multiple implementations and can provide objective evaluation of your current state. They often identify blind spots that internal teams miss and can benchmark your organization against industry standards and best practices.

When selecting external partners, prioritize those with demonstrated CMMC experience, relevant industry certifications, and strong references from similar organizations. Ensure they understand your specific industry requirements and operational constraints.

Establish Documentation Standards That Support CMMC 2.0 Certification

Establish robust documentation standards early in your gap analysis process. Create templates for gap identification, remediation planning, and progress tracking that align with CMMC assessment expectations. Implement version control and approval processes that will support your eventual certification efforts.

Develop a centralized repository for all CMMC-related documentation, including policies, procedures, assessment results, and remediation evidence. This repository will become invaluable during your actual CMMC assessment.

CMMC 2.0 Gap Analysis Risk Assessment: Business Impact Analysis

Organizations that neglect proper CMMC 2.0 gap analysis face significant business, financial, and reputational consequences that extend far beyond simple compliance failures.

Contract Loss Risks That Threaten Defense Revenue Streams

The most immediate risk of CMMC non-compliance is the loss of DoD contracts, which represent over $400 billion annually in the defense industrial base. Organizations without proper certification will be unable to bid on new contracts or renew existing agreements, potentially eliminating entire revenue streams.

Secondary impacts include loss of subcontracting opportunities, as prime contractors increasingly require CMMC compliance from their supply chain partners. This ripple effect can devastate smaller organizations that depend heavily on defense-related revenue.

Data Breach Costs That Multiply Without CMMC 2.0 Compliance

Poor cybersecurity controls increase the likelihood of successful cyberattacks targeting CUI and other sensitive information. Data breaches involving government information can result in significant financial penalties, legal liability, and remediation costs that often exceed millions of dollars.

Organizations may also face suspension or debarment from future government contracting opportunities following security incidents, multiplying the long-term financial impact of inadequate cybersecurity investments.

Competitive Disadvantage From Poor CMMC 2.0 Preparation

CMMC compliance has become a competitive differentiator in the defense contracting market. Organizations with strong cybersecurity postures can leverage their certification status to win new business and command premium pricing for their services.

Conversely, organizations that struggle with CMMC compliance may find themselves excluded from industry partnerships, joint ventures, and teaming arrangements that are increasingly common in defense contracting.

CMMC 2.0 Remediation Roadmap Development Strategy

An effective remediation roadmap transforms your gap analysis results into actionable implementation plans that balance compliance requirements with business constraints and available resources.

Build a Prioritization Framework That Maximizes CMMC 2.0 ROI

Develop a systematic approach to prioritizing identified gaps based on multiple factors including compliance risk, implementation complexity, cost, and business impact. Consider quick wins that can demonstrate progress while planning for larger infrastructure investments that may require multiple budget cycles.

Factor in dependencies between different remediation efforts, ensuring that foundational improvements are completed before implementing controls that build upon them. For example, implementing comprehensive logging before deploying advanced threat detection capabilities.

Develop Realistic Timelines for CMMC 2.0 Implementation Success

Create realistic timelines that account for procurement cycles, implementation complexity, and organizational change management requirements. Most organizations require 12-18 months for comprehensive CMMC 2.0 remediation, though simpler implementations may be completed more quickly.

Establish clear milestones and success criteria for each phase of your remediation effort. Regular progress reviews help maintain momentum and allow for course corrections when obstacles arise.

Calculate Total Budget Requirements for CMMC 2.0 Compliance

Develop comprehensive budget estimates that include technology costs, professional services, internal labor, and ongoing operational expenses. Many organizations underestimate the total cost of CMMC compliance by focusing solely on technology investments while ignoring process changes and documentation requirements.

Consider both one-time implementation costs and recurring operational expenses when building your business case for CMMC investment. Include potential cost savings from improved cybersecurity posture and operational efficiencies.

Your Path to CMMC 2.0 Compliance Success

Performing a comprehensive CMMC 2.0 gap analysis is the critical foundation for achieving certification and maintaining competitive advantage in defense contracting. The systematic 9-step process outlined in this guide ensures organizations properly assess their current security posture against all applicable controls, whether targeting Level 1’s 17 basic practices, Level 2’s 110 security controls, or Level 3’s 134 advanced requirements.

Success requires understanding that gap analysis complexity scales dramatically with certification levels—from simple 1-3 week CMMC Level 1 assessments to the other end of the spectrum: comprehensive 8-12 week CMMC Level 3 evaluations requiring specialized expertise. Organizations that invest early in thorough gap analysis, engage qualified third-party experts when needed, and prioritize documentation alongside technical controls position themselves for efficient compliance achievement while building robust cybersecurity programs that provide lasting business value.

The path forward demands immediate action, as CMMC 2.0 implementation phases begin in 2025 with contract requirements taking effect across the defense industrial base. Organizations that delay gap analysis risk losing competitive positioning, facing rushed remediation efforts, and potentially missing critical contract opportunities worth billions in defense spending.

Kiteworks provides a comprehensive solution that addresses multiple CMMC 2.0 requirements across all certification levels through its integrated Private Data Network platform. In fact, Kiteworks supports nearly 90% of CMMC 2.0 Level 2 compliance controls out of the box. As a result, DoD contractors and subcontractors can accelerate their CMMC 2.0 Level 2 accreditation process by ensuring they have the right sensitive content communications platform in place.

Kiteworks’ advanced FIPS 140-3 Level 1 validated encryption and granular access controls satisfy stringent CUI protection requirements for CMMC Level 2 and CMMC Level 3 compliance, while its comprehensive audit logs and automated reporting capabilities provide the detailed documentation evidence required for successful CMMC assessments.

Also, The platform’s automated policy enforcement reduces manual compliance efforts and human error risks, and its centralized content governance helps organizations maintain clear visibility and control over sensitive information flows throughout their infrastructure, supporting both gap analysis activities and ongoing compliance monitoring.

To learn more about Kiteworks and CMMC compliance, schedule a custom demo today.

Additional Resources

• Blog Post CMMC Compliance for Small Businesses: Challenges and Solutions
• Blog Post CMMC Compliance Guide for DIB Suppliers
• Blog Post CMMC Audit Requirements: What Assessors Need to See When Gauging Your CMMC Readiness
• Guide CMMC 2.0 Compliance Mapping for Sensitive Content Communications
• Blog Post The True Cost of CMMC Compliance: What Defense Contractors Need to Budget For