CMMC has rapidly become one of the most demanding compliance frameworks facing Defense Industrial Base (DIB) contractors. For small and mid-size organizations—particularly manufacturers, engineering firms, and service providers—the effort required to achieve and maintain CMMC Level 2 is significantly higher than anticipated.
Most companies expect a “cybersecurity checklist.” Instead, they encounter a full transformation of IT operations, documentation, governance, and evidence collection.
Below is a deeper look at why CMMC is so difficult and why costs are rising across the industry.
1. NIST 800-171 Was Written for Mature Enterprises — Not Small Vendors
CMMC Level 2 maps to the 110 controls in NIST SP 800-171, which themselves derive from NIST 800-53—a framework originally built for federal agencies and major government integrators.
This heritage means the underlying expectations assume the organization already has:
- A formal change management program with approvals, documentation, rollback procedures, and tracked changes.
- A functioning risk management process with risk registers, scoring, and recurring reviews.
- Documented IT procedures for provisioning, backups, onboarding, and patching.
- Centralized logging and monitoring through SIEM or log analytics.
- Defined role-based access control (RBAC).
- Proper network segmentation and boundary protection.
- A structured incident response process with roles and evidence retention.
Most small businesses have never operated at this level of maturity. The difference between their current state and what 800-171 expects is why CMMC efforts escalate quickly.
2. Assessors Must Evaluate Evidence — Not Intent
A CMMC assessment is not a “review conversation.” It is a formal evidence-based audit.
Assessors do not evaluate whether a company is trying to be compliant—they evaluate whether each requirement is “met” with independently verifiable artifacts. Typical evidence includes:
- Screenshots, configuration exports, log files, and system reports showing technical enforcement across all in-scope systems, including timestamps and settings that align directly with the documented procedures.
- Formal policies, standards, and SOPs aligned to each requirement, written clearly enough for assessors to trace how each control is defined, executed, and maintained over time.
- Ticketing records documenting provisioning, approvals, changes, vulnerability remediation, access removal, and any deviations from baseline configurations.
- Detailed audit trails generated automatically by systems, capturing events such as access attempts, administrative actions, configuration changes, and failed authentications.
- Logging outputs from endpoints, firewalls, servers, SaaS applications, and cloud platforms that demonstrate visibility, monitoring, and correlation of security events.
- Interview responses that match written procedures and evidence, confirming that staff understand, follow, and can explain the documented processes.
Many contractors underestimate the quantity and quality of evidence required. What feels like a simple control often requires 3–7 separate artifacts to demonstrate maturity.
3. Documentation Requirements Are Massive
Every one of the 110 practices—and nearly every assessment objective—needs to be supported by:
- A formal policy
- A detailed SOP or operating procedure
- Logged evidence or ticketing history
- Technical configuration that aligns to the policy
- A defined responsible role or owner
- A repeatable, enforceable process
Even a small 15–30 employee organization typically needs:
- 750–1,500+ pages of documentation
- 14 Policy documents–1 per control family
- 5–10 SOPs documenting processes
- Roles & responsibilities matrix
- Risk, configuration, and incident response registers
- Recurring evidence logs such as monthly scans, bi-weekly log reviews, or annual IR testing
- Shared Responsibility Matrix–showing responsibilities shared with service providers
The documentation burden—not the technology—is the biggest shock for most organizations and the primary driver of project cost.
4. CMMC Requires Maturity, Not One-Time Fixes
CMMC is built around process maturity, not configuration.
A company cannot simply configure Microsoft 365, turn on MFA, and declare victory. Assessors expect to see proof that processes are:
- Followed consistently
- Documented
- Repeatable
- Traceable
- Measured
This includes:
- Change control tickets for system updates
- Monthly vulnerability scans with remediation tasks
- Daily or weekly log review tickets
- Formal user provisioning and deprovisioning workflows
- Yearly incident response tabletop exercises
- Quarterly system and risk reviews
These recurring obligations require time and personnel—often the most expensive part of CMMC compliance.
5. Required Tools Are Expensive — and Difficult to Configure Correctly
The technical controls in 800-171 require enterprise-class tools and advanced configurations many small businesses have never implemented.
CMMC-relevant tools require configuring:
- SIEM/log analytics with long-term retention and tamper protection.
- EDR/XDR with strict policy enforcement and continuous monitoring.
- Intune/MDM with hardened compliance policies and encryption enforcement.
- Azure Key Vaults with RBAC, network controls, and purge protection.
- FIPS-validated cryptography enforced across endpoints and servers.
- Hardened configuration baselines mapped to 800-171 requirements.
Licensing is costly, but the real challenge is configuring these tools correctly—something that requires specialized expertise.
Even optimized environments often face tool costs of $30,000–$80,000 per year, before labor and MSP/MSSP support costs are included.
6. Microsoft GCC High Adds Significant Cost
For many contractors, CMMC readiness requires migrating from a Microsoft 365 commercial tenant into GCC or—when handling ITAR-controlled data—into GCC High. These migrations carry substantial licensing, engineering, and operational costs, GCC-H in particular.
GCC and GCC High migrations require:
- Complex tenant-to-tenant migrations for mail, identities, SharePoint, OneDrive, and Teams.
- Advanced identity hardening and Conditional Access architecture.
- Rebuilding Intune device compliance, configuration profiles, and application deployments.
- Re-evaluating third-party integrations, many of which do not support GCC High.
- Strict U.S.-person workforce requirements for ITAR environments.
- Producing detailed configuration evidence to satisfy C3PAO reviewers.
While GCC introduces moderate cost increases, GCC High carries significantly higher licensing and support costs, and is only required for organizations that receive or store ITAR-restricted data. For many SMBs, tenant migration is one of the largest and most disruptive phases of CMMC preparation.
For many small manufacturers, GCC High becomes the single largest budget item in their ongoing CMMC program.
7. The C3PAO Audit Process Itself Is Expensive
CMMC assessments are deep technical audits performed by certified third-party assessors, and this level of scrutiny is costly.
A C3PAO assessment includes:
- Detailed scoping sessions to define the CUI boundary.
- Multi-day interviews with executives and IT/security staff.
- Review of policies, SOPs, evidence logs, and configurations.
- Technical validation of enforcement across systems.
- Cross-verification between interviews and artifacts.
- Final assessment reporting and certification decisions.
With standard assessments costing $30,000–$60,000, the audit itself is a major financial component of the CMMC requirement.
8. Most Contractors Lack In-House Cybersecurity Staff
CMMC assumes that an organization has multiple dedicated security and governance roles with the authority, time, and expertise to oversee compliance activities. In reality, most small contractors rely on a single IT generalist who is already stretched thin supporting day-to-day operations, user issues, and production workloads.
Required roles typically include:
- A Security Manager overseeing governance, policy enforcement, and continuous monitoring.
- A System Owner responsible for architecture, system approvals, and documented security decisions.
- A Configuration/Change Manager overseeing updates, changes, baselines, and approval workflows.
- A Logging Analyst performing regular log reviews, documenting findings, and escalating anomalies.
- An Incident Response Lead coordinating investigations, evidence preservation, and reporting.
- A Risk Officer reviewing risks, assigning scores, tracking mitigations, and managing risk acceptance.
These roles require different skill sets, different responsibilities, and consistent ongoing activity. Because they cannot realistically be consolidated into one person, many SMBs must rely heavily on external MSP/MSSP support—yet still maintain internal ownership, decision-making authority, and documented participation to satisfy CMMC requirements.
9. Many Organizations Do Not Know Where CUI Is Stored or How It Flows Through Their Environment
One of the biggest challenges in CMMC preparation is that many organizations simply do not know where CUI is located, how it enters their systems, or how it moves across users, applications, and devices. Most small-business environments evolved organically, without data mapping, flow diagrams, or visibility into how sensitive information travels.
Common issues include:
- Unclear data entry points, such as portals, email attachments, engineering systems, or supplier submissions.
- Unknown storage locations, with CUI scattered across file shares, desktops, cloud apps, personal devices, or legacy servers.
- Uncontrolled data flows, where files move through Teams chats, email forwarding, USB devices, or unmonitored SaaS platforms.
- Lack of system boundaries, making it unclear which devices, users, and networks actually process or store CUI.
- Hidden CUI sprawl, caused by syncing tools like OneDrive, SharePoint libraries, or endpoint caching.
- No documented or enforced data lifecycle, including retention, archival, and destruction procedures.
Before an environment can be secured, organizations must identify exactly where CUI lives and how it flows. This often requires data discovery, mapping, segmentation, and implementing strict storage and access controls—changes that can fundamentally reshape the IT architecture.
10. “Audit Readiness” Takes Months, Not Weeks
A typical realistic timeline for achieving Level 2:
- 6–12 months for smaller, simple environments
- 12–24 months for larger or more complex environments
During this period, organizations must:
- Rewrite or create all required policies and SOPs
- Implement new technical tools
- Harden Microsoft 365 or GCC High
- Train all users on CUI handling
- Establish evidence-generation processes
- Conduct mock audits
- Resolve vulnerabilities and configuration gaps
This is not a quick project—it's a transformation of IT operations and corporate governance.
In Short: CMMC Is Hard Because It Requires SMBs to Operate Like Mature/Large Defense Organizations
CMMC requires a 20-person company to implement the governance, documentation, and monitoring typically seen in agencies like the Air Force, Navy, or DoD CIO.
It forces:
- Cultural change
- Governance discipline
- New tools
- New roles
- New documentation requirements
- Continuous processes—not one-time fixes
This is why costs appear high—and why companies that start early have the highest chance of success and the lowest long-term expense.