What Should Be on Your CMMC Compliance Checklist?

In today's cybersecurity climate, compliance isn't just a best practice-it's a necessity. For contractors and subcontractors in the U.S. defense industrial base (DIB), adhering to the Cybersecurity Maturity Model Certification (CMMC) is essential for maintaining eligibility for Department of Defense (DoD) contracts. The process of achieving and maintaining certification can be complex, but a well-structured CMMC compliance checklist (https://www.lgnetworksinc.com/what-is-cmmc-compliance/) can provide clarity, structure, and momentum.

Whether you're preparing for your first CMMC assessment or planning to level up to a higher maturity level, this comprehensive checklist will help ensure you're on the right track.

• What is CMMC?

The Cybersecurity Maturity Model Certification is a unified standard created by the DoD to ensure all its contractors have robust cybersecurity measures in place to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI).

CMMC is evolving-CMMC 2.0 is the latest iteration, reducing five maturity levels to three and streamlining requirements for many organizations. But regardless of which version you're preparing for, the core principles of cybersecurity hygiene, risk management, and continuous improvement remain intact.

• Why You Need a CMMC Compliance Checklist

Given the complexity and depth of CMMC requirements, a structured compliance checklist provides multiple advantages:

Organization: Tracks progress across dozens of practices and processes.
Readiness: Prepares you for third-party assessments or self-assessments.
Risk Mitigation: Helps identify and close security gaps before they become breaches.
Contract Eligibility: Demonstrates your eligibility for DoD contracts, increasing competitiveness.

Let's break down the essential components of a robust CMMC compliance checklist.

1. Determine Your Required CMMC Level

The first step is identifying which CMMC level applies to your organization:

Level 1: Basic cyber hygiene, required for handling FCI.
Level 2: Intermediate cyber hygiene, required for handling CUI. Equivalent to NIST SP 800-171.

Level 3: Expert cybersecurity, aligned with a subset of NIST SP 800-172.

📌 Checklist Item:

☐ Review your contracts to determine whether you handle FCI, CUI, or both.
☐ Confirm which CMMC level your organization must meet.

2. Understand CMMC Domains and Practices

CMMC is built around cybersecurity domains, such as:
Access Control (AC)
Incident Response (IR)
Risk Management (RM)
System and Communications Protection (SC)

Each domain contains a series of practices (technical requirements) and processes (management maturity).

📌 Checklist Item:

☐ Download and study the latest CMMC Assessment Guide for your required level.
☐ Map each domain's practices to your current IT and security controls.

3. Perform a Gap Analysis

A gap analysis compares your current cybersecurity posture to CMMC requirements. It helps you understand what's already in place and what needs improvement.

📌 Checklist Item:

☐ Conduct a self-assessment using tools like the DoD's Project Spectrum or NIST 800-171A.
☐ Document areas of non-compliance or missing controls.
☐ Prioritize remediation efforts based on risk.

4. Develop and Update Policies and Procedures

Many CMMC practices require documented, consistently applied policies and procedures. If you don't have formal documentation-or if it's outdated-now is the time to write or revise it.

📌 Checklist Item:

☐ Create or update policies for access control, incident response, configuration management, and more.
☐ Ensure procedures are aligned with CMMC requirements and reflect actual operational practices.
☐ Implement policy training for staff.

5. Implement Technical Controls

This is where cybersecurity tools and infrastructure come into play. Many CMMC practices require organizations to deploy specific technical safeguards.

📌 Checklist Item:

☐ Enforce Multi-Factor Authentication (MFA) for all sensitive systems.
☐ Configure audit logs and ensure log monitoring is in place.
☐ Use encryption for data in transit and at rest.
☐ Harden endpoint devices and restrict access via role-based access control.

6. Establish an Incident Response Plan (IRP)

Incident response is a critical focus of CMMC. You must be prepared to detect, report, and recover from cybersecurity incidents efficiently.

📌 Checklist Item:

☐ Develop a formal IRP with defined roles, responsibilities, and escalation paths.
☐ Conduct tabletop exercises or simulations to test response capabilities.
☐ Document lessons learned and update your IRP regularly.

7. Control and Monitor Access to Systems

Access Control (AC) is one of the most heavily weighted domains in CMMC. You must limit access to authorized users and monitor user activity.

📌 Checklist Item:

☐ Review user access rights regularly and remove unnecessary privileges.
☐ Use centralized identity and access management (IAM) tools.
☐ Set up logging and alerts for anomalous behavior or unauthorized access attempts.

8. Train Your Team on Cybersecurity Awareness

Employees can be the weakest link or your first line of defense. Ongoing training is essential to meet CMMC's expectations around awareness and responsibility.

📌 Checklist Item:

☐ Conduct mandatory cybersecurity training for all staff at least annually.
☐ Include phishing awareness, password hygiene, and reporting procedures.
☐ Maintain training records for compliance documentation.

9. Document a System Security Plan (SSP)

An SSP is a foundational document required under NIST 800-171 and CMMC. It outlines your environment, systems, and how CMMC requirements are being met.

📌 Checklist Item:

☐ Create or update your SSP with detailed descriptions of each control and how it's implemented.
☐ Include network diagrams, system boundaries, and technology descriptions.
☐ Store the SSP securely and keep it current.

10. Maintain a Plan of Action and Milestones (POA&M)

If your organization isn't fully compliant yet, a POA&M outlines the steps you're taking to close the gaps. While not allowed for certification delays in CMMC Level 2+ assessments, a POA&M is still a useful internal tracking tool.

📌 Checklist Item:

☐ List incomplete controls with target dates and remediation plans.
☐ Assign ownership for each action item.
☐ Regularly review and update progress.

11. Prepare for the Assessment Process

Depending on your required CMMC level, you'll need to either perform a self-assessment or undergo a third-party evaluation by a C3PAO (Certified Third Party Assessment Organization).

📌 Checklist Item:

☐ Collect and organize all documentation and evidence.
☐ Conduct a mock assessment or internal audit.
☐ Engage a C3PAO early to schedule an official assessment, if applicable.
☐ Be prepared for follow-up questions and requests for clarification.

12. Implement Continuous Monitoring

CMMC is not a one-and-done framework. You must continuously monitor your security posture and adapt as threats evolve.

📌 Checklist Item:

☐ Set up regular reviews of controls, logs, and system configurations.
☐ Schedule periodic risk assessments and internal audits.
☐ Stay informed about changes to CMMC, NIST, and DoD requirements.

• Final Thoughts

Achieving CMMC certification is not simply a checkbox activity-it's an ongoing commitment to cybersecurity excellence. A detailed CMMC compliance checklist can help you reduce risk, improve efficiency, and prepare for the rigorous expectations of the DoD contracting environment.

By taking a proactive and structured approach-backed by accurate documentation, strong policies, and technical enforcement-you can turn compliance into a strategic advantage. Whether you're in early preparation or final review, this checklist will serve as your go-to resource for navigating the CMMC landscape.

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