How Small Businesses Can Navigate CMMC Certification

There are an estimated 80,000 Department of Defense (DoD) contractors that handle Controlled Unclassified Information (CUI) and will be required to achieve Cybersecurity Maturity Model Certification (CMMC) Level 2 (L2) certification. Some of these companies are large, but it is estimated that over 70% of these firms are small businesses with very limited or no internal dedicated IT/security staff. Achieving CMMC L2 compliance is challenging for small businesses as they are required to implement and maintain compliance with the full set of 110 security requirements, the same as much larger firms but with considerable resource limitations.

The following steps are tailored specifically for small organizations to streamline their CMMC L2 compliance journey efficiently and affordably.

The smaller your CMMC scope, the easier and more affordable your compliance journey will be. For small businesses, scoping is your opportunity to limit the number of systems, users, and processes that are needed to meet CMMC L2 requirements:

• Identify the systems and people that truly need access to CUI
• Limit the number of users, systems, and services that handle CUI
• Keep your CMMC boundary tight to reduce complexity, effort, and cost

Clearly understanding your CMMC scope helps ensure you focus your resources only where they’re needed and that you don’t miss any required controls as you move forward.

2. Create Documentation Throughout the Process

Start building your System Security Plan (SSP) and policy documentation early—don’t wait until the end. Since your CMMC scope information goes in the opening sections of the SSP, getting a head start helps set the foundation. Keep policies short, relevant, and tailored to how your small team operates.

Documenting as you go reduces the need for expensive catch-up work later and ensures greater accuracy while the information is still fresh in your mind.

3. Leverage External Service Providers (Control Inheritance is Critical)

Use of External Service Providers (ESPs) is the best method that small businesses can leverage to fast-track their CMMC compliance journey. These could be Cloud Service Providers (CSPs) that are FedRAMP compliant, managed service providers (MSPs) that are already CMMC L2 certified, or other service providers that are not CMMC certified but are willing to provide evidence that the security controls that they provide you are CMMC compliant.

When evaluating ESPs:

• Choose CSPs that have met FedRAMP Moderate or High authorization levels
• Favor working with MSPs and MSSPs that are themselves CMMC L2 compliant
• Ask for Shared Responsibility Matrices (SRMs) from CSPs and CMMC L2 compliant MSPs
• Ask non-CMMC certified MSP and MSSPs to document which CMMC controls they are responsible for, and confirm their willingness to participate in your CMMC L2 assessment for those controls.
• Seek to work with ESPs that provide integrated security platforms or suites that cover multiple technical controls—such as access control, logging, device protection, and data encryption—in a unified way. These can simplify management, reduce tool sprawl, and lower costs.
• Track which requirements are inherited, shared, or owned internally in your SSP as you describe each control. This helps keep responsibilities clear without extra complexity.

4. Conduct a Practical CMMC L2 Gap Assessment

Perform a practical and right-sized gap assessment against all 110 NIST SP 800-171 controls to identify where your organization stands. This helps you avoid guesswork and obtain the input needed to build an efficient roadmap to CMMC L2 compliance.

• Only consider in-scope elements such as systems, locations, and people
• Start by identifying inherited controls and marking these as “covered” in your gap assessment
• Use simplistic, low-cost solutions to track your gaps. Using a spreadsheet, for example, can be a good way to start for small businesses to avoid the additional cost related to purchasing a tracking system.
• Identify which of the L2 controls are also needed for CMMC Level 1 (L1) compliance
• Track your control gaps at the assessment objective level. [This will avoid later rework since the Certified Third-Party Assessment Organization (C3PAO) must assess your compliance with each objective.]

The CMMC L1 control requirements form the foundation of good cyber hygiene and are a subset of the L2 requirements. During the CMMC L2 gap assessment process, it’s often discovered that the 17 L1 requirements can be implemented considerably faster than the full set of 110 L2 requirements.

By addressing the L1 requirements first, a company can complete a self-assessment and submit the results in the DoD’s Supplier Performance Risk System (SPRS) to self-attest to CMMC L1 compliance.

The 17 L1 requirements are typically low-cost, high-impact controls. Achieving CMMC L1 compliance demonstrates your company’s commitment to cybersecurity and qualifies you for DoD contracts that require it.

Keep in mind that security awareness and role-based training are required for all in-scope personnel. For small teams, this doesn’t need to be complicated or expensive. Consider in-house developed programs, free resources, or bundled MSP/MSSP services to meet this requirement efficiently. Be sure to track training completion as part of your SSP documentation.

Working with a CMMC certified consultant, such as a Certified CMMC Professional (CCP) or Certified CMMC Assessor (CCA), can save a small business considerable time and money on their journey to achieving CMMC L2 certification. These certified professionals receive the same training as C3PAO assessment team members, so they have deep insight into what assessors will require during a CMMC L2 assessment. This level of expertise helps you avoid wasted effort, misinterpretation of requirements, and costly rework.

For small businesses just starting their CMMC journey, free resources like Project Spectrum offer educational materials, self-assessment tools, and planning resources designed for small and mid-sized organizations. Many smaller businesses use it to build early awareness and organize their next steps.

As you begin actively preparing for certification, working with a CMMC-certified consultant can provide personalized support to ensure your documentation, technical controls, and policies align with assessment expectations, helping you avoid surprises during the audit process.

Key benefits of partnering with a CMMC certified consultant include:

• Helping you focus on what matters most and avoid over-engineering solutions
• Providing templates for all required CMMC documentation, tailored for small businesses, to fast-track your compliance process
• Offering access to compliance tracking software to efficiently monitor progress and remediation efforts
• Offering white-glove, ongoing support throughout the entire process. (Consider giving special priority to CMMC-certified consultants who also provide virtual CISO (vCISO) or security advisory services, as their experience can be invaluable for small teams wanting ongoing guidance.)

Note: A CCP or CCA serving as a consultant cannot also participate as part of your official CMMC assessment team. This separation helps maintain independence and objectivity in the certification process.

By following these practical, cost-conscious steps, small businesses can successfully achieve CMMC L2 compliance without becoming overwhelmed. Focus on sequencing, leveraging provider services, and building as you go to maximize your return on effort.

Need help navigating CMMC? Our certified team can help small businesses prepare for the certification process with confidence. Explore our CMMC readiness services and get started today.