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The Essential Kiteworks Guide to CMMC 2.0 Compliance

by Tim Freestone updated June 13, 2024 CMMC Compliance

Reading Time: 7 minutes

CMMC 2.0 is the latest version of the cyber security framework established by the U.S. Department of Defense (DoD) to ensure that contractors within the Defence Industrial Base (DIB) safeguard critical sensitive information.

The goal: protect national security and ensure the integrity of sensitive defence information.

Building upon the original CMMC framework, CMMC 2.0 streamlined and simplified various parts of the framework, making it more adaptable and approachable for organisations of various sizes.

Below, we explore why CMMC 2.0 is crucial, what’s changed from the previous version, and how your organisation can achieve and maintain compliance for the level needed.

Why is CMMC 2.0 important?

CMMC 2.0 is critical for protecting Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) within the defence supply chain. By adhering to the standards laid out, DIB organisations can confidently demonstrate their commitment to robust cyber security: essential for securing contracts, maintaining trust, and mitigating cyber threats.

CMMC 2.0 vs 1.0, what’s changed?

CMMC has seen significant changes in the shift from version 1.0 to 2.0.

One of the core differences here is the reduction in the number of maturity levels. Previously, CMMC 1.0 had five levels, ranging from basic cyber hygiene to advanced practices.

Now, CMMC 2.0 has consolidated these five into three.

The purpose? A simplified framework and reduced compliance costs, especially for small businesses.

Assessment requirements have also been revised under CMMC 2.0. While version 1.0 mandated third-party assessments for all levels, CMMC 2.0 has introduced a more flexible approach.

Now, Level 1 contractors are permitted to conduct annual self-assessments, with third-party assessments only mandatory for contractors involved in which require Level 2 certification. Level 3 assessments remain led by government departments.

Who needs to be CMMC compliant?

Complying with CMMC 2.0 will be mandatory for any contractor and subcontractor in the Defense Industrial Base (DIB) who handles Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), ensuring that any stakeholder involved is implementing appropriate cyber security measures to protect sensitive information from cyber threats.

Discover more about what’s changed, and what level you need, in our full report.

Understanding the three maturity levels

CMMC 2.0 introduces three distinct maturity levels, each with increasing requirements and responsibilities:

Level 1 – Foundational
Level 2 – Advanced
Level 3 – Expert

Level 1 – Foundational

This level includes basic cyber security practices such as implementing access controls and conducting regular training. To certify compliance with level 1, relevant organisations need to perform annual self-assessments against these basic standards.

Level 2 – Advanced

Building on Level 1 and Level 2 requires organisations to implement all 110 security controls from NIST SP 800-171. To certify compliance at this level, organisations handling critical national security information must undergo triennial assessments by a dedicated invigilator, referred to as a ‘CMMC Third Party Assessor Organization’ (C3PAO).

Some of these measures include:

Employing cryptography to safeguard the confidentiality of remote sessions
Automatically terminating user sessions that meet defined conditions
Monitoring and controlling all access via mobile devices
Separating the duties of individuals to reduce the risk of malicious actions
Preventing the execution of privileged functions from non-privileged accounts

Learn more about CMMC Level 2 in our deep dive today.

Level 3 – Expert

Mandating the highest measures of robust security, CMMC 2.0 level 3 focuses on protecting against advanced persistent threats (APTs). It includes numerous additional controls from NIST SP 800-171 and NIST SP 800-172, requiring rigorous government-led triennial assessments.

CMMC Model

What are the 8 steps to achieving CMMC 2.0 compliance?

While achieving CMMC 2.0 compliance may seem formidable, we want to help ensure that you’re as confident as possible as you take steps to bolster your security processes.

Below, we’ve outlined the eight essential steps to achieving CMMC 2.0 for your enterprise.

At a glance, these steps are:

Get familiar with CMMC 2.0 requirements
Perform a gap analysis
Develop a System Security Plan
Implement security controls
Create a POA&M
Conduct an internal assessment
Liaise with third-party assessors
Ensure that you maintain compliance

1. Get familiar with CMMC 2.0 requirements

Begin by familiarising yourself with the three CMMC 2.0 levels: foundational, advanced, and expert. The Department of Defense (DoD) will inform your organisation of its designated level. Once clarified, thoroughly understand the specific controls and requirements associated.

2. Perform a gap analysis

The next step involves conducting a thorough gap analysis. Compare your current cyber security practices against the requirements specified for your designated CMMC level to understand your strengths and vulnerabilities in more detail.

This analysis should involve a detailed examination of your existing security controls, policies, and procedures to identify deficiencies and areas needing enhancement to meet the compliance standards necessary.

3. Develop a system security plan

Once a gap analysis has been reached, formulate a comprehensive System Security Plan (SSP) that delineates your organisation’s security controls and measures. This document should outline how your organisation intends to protect sensitive information and comply with CMMC requirements.

An effective SSP will include details on system boundaries, environments of operation, and how to implement security controls.

4. Implement security controls

With your system security plan created, it’s time to implement the necessary security controls as per your determined CMMC level.

These controls should encompass critical areas such as access controls, incident response, configuration management, and system and communication protection. Effectively deploy these controls, and you will bolster your organisation’s cyber security posture and safeguard CUI from potential threats.

5. Create a POA&M

Develop a plan of action and milestones (POA&M) to address identified gaps from your analysis. This plan should detail the steps required to achieve compliance, including specific tasks, responsible parties, timelines, and milestones. A well-structured POA&M helps to systematically improve your security measures and ensure timely compliance.

6. Conduct an internal assessment

It’s also important to make sure that you regularly perform internal assessments to evaluate your compliance status. These assessments also help ensure that any new security measures have been properly implemented and are functioning as intended.

But these assessments aren’t meant to be purely reactive. They should also serve as a proactive approach to identify and rectify potential issues before formal evaluations by third-party assessors.

Discover our tips for conducting self-assessments today.

7. Liaise with third-party assessors

CMMC Level 2 makes it necessary to engage with a CMMC Third Party Assessor Organisation (C3PAO) for an official assessment on a triannual basis.
These assessors will validate your compliance efforts and certify your organisation accordingly. Throughout the assessment process, it’s crucial to maintain open communication and transparently cooperate with the C3PAO to ensure a smooth and efficient assessment process.

Learn more insights on compliance from a CMMC expert today.

8. Ensure that you maintain compliance

It’s important to understand that compliance is an ongoing process.

Continuously update your security measures, conduct regular assessments, and stay informed about changes in CMMC requirements. Maintaining compliance involves an iterative cycle of monitoring, evaluating, and adjusting practices to ensure sustained adherence to CMMC standards.

We’ve gone into more detail on the 8 critical steps involved in ensuring CMMC 2.0 compliance in our full blog. Learn more today.

Understanding the common CMMC 2.0 challenges

Reaching compliance with CMMC 2.0 presents several challenges for organisations, particularly those in the Defence Industrial Base (DIB). Three core challenges include:

Compliance cost and complexity
Taking on a long-term view for consistency
Conducting difficult and lengthy self-assessments

Compliance cost and complexity

One major challenge involved in the CMMC journey is the sheer cost and complexity of achieving and maintaining compliance. It’s a feat that involves not only the expenses for third-party assessments required at certain levels but also the significant costs and complexity associated with preparing for these assessments.

Updating legacy systems, upgrading traditional processes, and training personnel all come with potentially prohibitive costs – especially for small and medium-sized businesses. This can make compliance a substantial financial burden.

Training employees also poses a long-term knock-on effect on your overall resource, as does the regular auditing and documentation of new policies and procedures.

Taking on a long-term view for consistency

Maintaining long-term CMMC 2.0 compliance means consistently keeping up with new regulations, making sure all parts of the organisation are on the same page, and integrating new standards with existing systems.

This requires an ongoing investment into resources, as well as strong monitoring and reporting processes.

Conducting difficult and lengthy self-assessments

Conducting a self-assessment can seem daunting, complex, and lengthy, with a multitude of challenges. The primary challenge here is interpreting the language surrounding compliance standards, which often leads to misinterpretation and errors that can jeopardise your security.

What’s more, organisations often misjudge the depth of “implemented” controls, leading to a false sense of security and poor DoD assessments. It’s crucial for companies to thoroughly understand and accurately assess CMMC requirements to bridge this gap.

We go into more detail on common CMMC challenges for small businesses in our blog.

Fast-track your CMMC 2.0 compliance journey with Kiteworks SafeEDIT

Equipped with the right tool, achieving CMMC 2.0 compliance can be a breeze.

At Kiteworks, our dedicated tools enable organisations of any size to secure sensitive data, achieve compliance with a wide range of regulations – from DORA to GDPR – and allow external collaboration on sensitive files without transferring control.

Ready to enhance your organisation’s security and compliance? Book a demo with Kiteworks SafeEDIT today.

FAQs

CMMC 2.0 simplified the original framework, reducing the number of maturity levels from five to three and allowing for self-assessments at Level 1.

All contractors and subcontractors in the DoD supply chain must achieve CMMC 2.0 compliance at the appropriate level based on the sensitivity of the data they handle.

Level 1 requires annual self-assessments, while Levels 2 and 3 require triennial assessments by a C3PAO.

A CMMC Third Party Assessor Organization (C3PAO) authorized and certified by the CMMC Accreditation Body (CMMC-AB) to conduct assessments of contractors and subcontractors seeking certification to demonstrate compliance with the CMMC standard. C3PAOs are entrusted with assessing and certifying that companies in the defense industrial base (DIB) supply chain have met the cybersecurity requirements of the CMMC standard.

Self-assessments for Level 2 are allowed only under specific circumstances approved by the DoD. If you don’t fall under these conditions, a C3PAO assessment is mandatory.

Kiteworks’ FedRAMP Moderate Authorized platform for privacy and compliance governance enables organizations to send, share, receive, and store sensitive content. Integrating communication channels such as secure email, file sharing, file transfer, managed file transfer, web forms, and application programming interfaces (APIs), the Kiteworks platform creates private content networks that track, control, and secure confidential digital communications while unifying visibility and metadata. Kiteworks supports nearly 90% of Level 2 requirements out of the box.

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