NIST 800-171 defines the specific controls (technical, administrative, and physical) needed to protect data. CMMC is the process of verifying that those controls are in place. 

CMMC uses a three-tier model tailored to the type of data a contractor handles. Most DIB contractors fall into Level 2: vendors who store, process, or transmit CUI. CMMC Level 2 maps directly to the 110 security controls outlined in NIST 800-171 Revision 2. Organizations that have fully implemented and operationalized NIST 800‑171 controls are better positioned to pursue CMMC Level 2, though additional documentation and evidence are typically required.

While the controls are the same, proving compliance under CMMC is much tougher. In a standard NIST self-assessment, a company might point to a policy document stating that it uses multi-factor authentication (MFA). In a CMMC Level 2 assessment, a third-party (C3PAO) auditor also demands proof of system configurations, audit logs, and personnel interviews to verify that the policy is working. Though some Level 2 contracts allow for self-assessment, this shift from "saying" to "showing" is where many organizations stumble.

For DIB business owners and executives, CMMC represents a seat at the table. While the Defense Federal Acquisition Regulation Supplement (DFARS) has long required contractors to implement NIST 800-171, compliance was often treated as a post-award activity. A vendor could win a bid, then develop a plan of action and milestones (POA&M) to address any security gaps. This created a culture of "perpetual remediation," where vulnerabilities were identified but never fully closed because the business had already secured the revenue.

CMMC, on the other hand, makes certification a prerequisite for contract eligibility. This turns compliance into a strategic business asset. An organization with an early CMMC certification may find itself a sole supplier for certain critical components while competitors are still waiting for C3PAO assessment slots.

Third-party assessment can also reduce legal risk by providing independent verification, though organizations remain legally accountable for the accuracy of all representations.

For internal IT and security teams, the transition to CMMC means following stricter documentation and evidence requirements. Under the NIST self-assessment model, documentation was often seen as secondary. With CMMC, the system security plan (SSP) becomes an essential, living document, serving as the foundation for audits and, therefore, contract eligibility. To support the SSP, teams must focus on gathering "artifacts" (screenshots, log files, signed training certificates, etc.) that prove a control was active at a specific time. 

CMMC certification is valid for a defined period (typically three years for Level 2) and requires annual executive affirmations that controls remain in place. Maintaining compliance over that period depends on continuous monitoring via tools such as security information and event management (SIEM) that automate evidence collection to avoid overwhelming staff.

The DoD expects CMMC requirements to be fully implemented across all applicable DIB contracts by 2028. Given that preparation can take 12–18 months, organizations must start today. Huntress Managed EDR, SIEM, and ITDR operationalize NIST 800-171 controls through real-time monitoring, detection, and documented response across endpoints and identities. Explore how Huntress can streamline your path to CMMC compliance with the right tech stack and assessor-ready documentation.