And Let’s Prove CMMC 2.0 Does Not Apply
Is it Commercial Off The Shelf COTS?
Do you make and sell Commercial Off The Shelf COTS products to the DoD or your prime customer? If so, NIST 800-171 and CMMC level 2 (and higher) requirements do not apply. The determination is often very nuanced. A COTS exemption saves the cost of an unnecessary CMMC 2.0 compliance program.
If you believe your products are Commercial Off The Shelf COTS and meet the requirements under applicable federal regulations, we can help you prove it.
How We Work Together – COTS
- We analyze the nature of the products you sell to your prime customers and/or the U.S. DoD to determine if they qualify for a COTS exemption.
- We assess your product functionality and configuration choices to verify they are not custom specifications or tolerances.
- If we establish that your product’s functionality and options are the same for your DoD and commercial market buyers, we prepare and document a COTS self-determination deliverable package for you to submit to your prime customers.
COTS Exemption
“We received those CUI/DFARS compliance letters from our three prime customers and were thrilled to learn (from KLC Consulting) that we qualify for a COTS exemption. All three approved! Thank you very much for your help in saving us over $150,000!”
– A Rhode Island manufacturer of precious metal alloys

COTS Package
One of our high-value service offerings, complete in 30-45 days.
We work together to provide:
- A COTS self-determination analysis report for each product in scope and a detailed summary as to whether it does or does not meet the DoD’s COTS qualification requirements
- One hour debrief call to present deliverable reports and answer all of your questions
- Relief from non-applicable CMMC level 2.0 and higher requirements (requires approval from the DoD or your prime contractor)
Prices start at $4,500
Dependent upon:
- Number of products
- Complexity of products
Not COTS? We’re ready to help you develop your CMMC compliance program
2 COTS Case Studies
2 KLC Consulting Clients Avoid Unnecessary CMMC Compliance Costs
Case Study #1: COTS exemption for a precision fluid dispensing equipment manufacturer
Case Study #2: COTS exemption for a manufacturer of precious metal alloys
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CMMC Consulting
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KLC Consulting’s DoD cybersecurity experts coordinate with your team to support all areas of NIST 800-171 and CMMC. Let’s get started on your CMMC Compliance program!