Schedule Your CMMC Level 2 Assessment Ahead of the Bottleneck
The race for CMMC Level 2 assessments is on, and it’s not hard to see why. With roughly 77,000 organizations seeking certification and fewer than 70 CMMC Third-Party Assessment Organizations (C3PAOs) available, the competition for assessment slots is heating up. If your organization contracts with the Department of Defense (DoD), the time to act is now. The days of viewing CMMC compliance as something to worry about “down the road” are over. CMMC was codified when it was published in October 2024, and it’s already appearing in DoD solicitations and contract requirements today.
DFARS 48 CFR Rule and Its Impact on Demand
One of the biggest factors driving today’s demand for C3PAOs is the imminence of the 48 CFR update, which starts the clock ticking on CMMC’s 36-month phase-in. Although the projected timing of its publication in the Federal Register is slated for Q3 2025, one thing is clear: The DoD is already moving forward with CMMC requirements, as evidenced by CMMC Level 2 requirements surfacing in draft sections of solicitations on SAM.gov. This signals that CMMC is here and it’s here to stay.
For Organizations Seeking Certification (OSCs), this is a wake-up call. The presence of CMMC Level 2 in contract solicitations means that companies bidding on DoD work must be assessed and certified as a prerequisite to meet compliance requirements. Those that aren’t certified won’t be eligible to participate in DoD contracts.
Clarification on Waivers and Self-Assessments
We’ve heard some uncertainty expressed about waivers and the possibility of continued self-assessments for CMMC Level 2, but the DoD has been crystal clear from the start that self-assessment for DoD CUI was never intended. The failure of the self-attestation model to protect CUI drives the need for independent verification by C3PAOs. Organizations handling Controlled Unclassified Information (CUI) will need to undergo a formal third-party assessment and obtain certification in Level 2 to demonstrate they’ve fully implemented the requisite security requirements.
Waivers, too, will be few and far between. Don’t expect uncertainty and procrastination to be acceptable justifications, given the painful history of our geopolitical adversaries stealing CUI to reverse-engineer our classified systems. The requirement to provide “Adequate Protection” for CUI outside of Federal Systems has existed since December 31, 2017, when the DoD began requiring it via DFARS 252.204-7012. CMMC is now 7+ years in the making, and its imminence has been communicated loudly and clearly throughout its gestation.
What This Means for OSCs
If your organization handles CUI and plans to continue DoD contracts, waiting is no longer an option. The approaching phase-in and limited number of C3PAOs mean time is of the essence. Here’s what’s driving the surge in demand:
1. Increased Urgency
The inclusion of CMMC requirements in draft solicitations creates urgency. Don’t be caught on the outside looking in when 48 CFR drops. Companies that don’t secure an assessment slot with a C3PAO soon will find themselves locked out of future DoD contracts.
2. Emphasis on C3PAO Credibility
Be selective in choosing your assessment provider. A “Candidate C3PAO“ is not an authorized C3PAO and may or may not ever become one. Partner with an authorized C3PAO that’s been in business for 15-20 years and is known to provide a collaborative assessment process.
3. Supply Chain Implications
Prime (Tier 1) defense contractors who share CUI with their subcontractors must ensure they, too, are CMMC compliant (a/k/a Flow Down Requirements). If you are a subcontractor to a DoD Prime, you’ve received queries and questionnaires about your progress with implementing CMMC requirements and attaining certification.
Key Indicators That CMMC is Already Here
Some organizations mistakenly believe they have time before CMMC compliance becomes mandatory. However, real-world examples prove otherwise. Here are some key observations:
Army MAPS Initiative
One of the most prominent indicators of CMMC enforcement is its inclusion in the Army’s Multiple Award Professional Services (MAPS) contract. This broad initiative explicitly requires CMMC Level 2 certification. The inclusion of CMMC Level 2 in a large Indefinite Delivery/Indefinite Quantity (IDIQ) contract like MAPS is a strong signal that the DoD is not wavering from its goal to verify improved cybersecurity practice implementation via C3PAO assessment before contract award.
SAM.gov and Draft Solicitations
Beyond MAPS, draft solicitations posted on SAM.gov increasingly reference CMMC Level 2 requirements. Even before the 48 CFR is updated, the DoD is clearly signaling its intent to enforce compliance. The presence of these requirements in early-stage solicitations highlights the importance of getting assessed sooner rather than later.
Increased Scrutiny in Solicitations
The DoD’s heightened focus on cybersecurity is evident in solicitation language. We’re seeing:
- Explicit requirements to comply with NIST SP 800-171.
- Requests for documented evidence of cybersecurity practices.
- A growing emphasis on supply chain cybersecurity.
For OSCs, these developments confirm that CMMC compliance is no longer hypothetical – it’s a current, pressing reality.
What Should Your Organization Do Next?
Don’t wait to schedule your CMMC Level 2 Certification Assessment. Select a C3PAO and get on their assessment calendar.
- Assess Your Readiness – Conduct a CMMC Gap Analysis or Mock Assessment (a practice-run readiness assessment). Identify any CUI scoping errors and compliance deficiencies between your current implementation and CMMC Level 2 requirements.
- Engage a C3PAO – With the limited number of authorized C3PAOs, securing an assessment slot sooner rather than later is of the utmost importance. Waiting will leave your organization needing an assessment but unable to schedule it.
- Implement Required Controls – If there are areas where your organization falls short, address them now. The sooner you meet CMMC requirements, the easier your certification process will be.
- Stay Informed – Keep an eye on DoD updates, especially 48 CFR in the Federal Register and soli SAM.gov.
Partner with authorized C3PAO – KLC Consulting
At KLC Consulting, we understand the urgency and challenge of CMMC compliance. We’re a fully authorized CMMC Third-Party Assessment Organization. And we’re different from other C3PAOs because we advocate for your success through collaborative CMMC Level 2 Certification Assessment services. We help you get where you need to be with confidence. Our services include:
- CMMC Readiness Assessments – Identifying gaps and preparing your organization for certification.
- CMMC Level 2 Assessments – Conducting official assessments to certify compliance.
With the demand for C3PAOs at an all-time high, now is the time to act. Don’t wait until assessment slots disappear—contact KLC Consulting today and take the first step toward securing your CMMC certification.
Would you like to know “How much will my CMMC Level 2 Certification Assessment cost?” You can get an INSTANT price quote here:
