In today’s fast-paced digital landscape, cybersecurity is of the utmost importance, especially for organizations operating in the Defense Industrial Base (DIB). In this context, the Cybersecurity Maturity Model Certification (CMMC) 2.0 becomes exceedingly relevant. Initiated by the U.S. Department of Defense (DoD), the CMMC framework introduces a streamlined standard for implementing cybersecurity controls across DIB contractors. The consequences of non-compliance can be severe, with potential contractual breaches, compromised data, and resulting reputational damage. Therefore, understanding, achieving, and maintaining CMMC compliance is not just a necessity, but a strategic move for any organization within this space. That’s why we will delve into the top 10 CMMC Compliance Failures.


top 10 cmmc compliance failures
Top 10 CMMC Compliance Failures


Despite the elevated stakes, compliance with CMMC remains a common challenge for many organizations. The reasons for this vary – some grapple with the intricacies of the updated requirements, while others fail to allocate the necessary resources or expertise to their cybersecurity initiatives. In this blog post, we explore the top 10 CMMC compliance failures. We will spotlight common pitfalls and provide insights on how to circumvent these errors in your journey towards achieving and sustaining CMMC compliance.

Understanding CMMC Compliance


A. Brief Overview of CMMC Compliance

Firstly, the Cybersecurity Maturity Model Certification (CMMC) framework outlines three maturity levels, each with a distinct set of required security controls, or practices, and processes. Beginning with basic cyber hygiene at Level 1 and progressing to “expert” at Level 3, the framework gradually escalates in the complexity and robustness of cybersecurity requirements.

Achieving CMMC compliance is not just about implementing these practices and processes. It also entails documenting and demonstrating your organization’s adherence to them in a manner that satisfies CMMC’s comprehensive assessments. Depending on the type of CUI and required certification level, these assessments may either be self-conducted or carried out by certified CMMC Third-Party Assessment Organizations (C3PAOs). These entities serve as the final arbiters of an organization’s CMMC compliance.

B. Introduction to the Top 10 CMMC Requirements

top 10 cmmc compliance failures

While all CMMC requirements are vital for a strong cybersecurity posture, certain aspects often pose significant challenges for organizations. Based on our experience and industry-wide data, we’ve identified the top 10 CMMC requirements where non-compliance is most frequent. These include:

  1. FIPS-validated cryptography
  2. Multifactor Authentication
  3. Identify, report, correct system flaws
  4. Periodically assess risk
  5. Scan for vulnerabilities
  6. Review and update logged events
  7. Audit logging process failure alerts
  8. Audit record review, analysis, and reporting processes
  9. Test incident response capability
  10. Establish/maintain baseline configuration

In the following sections, we’ll delve deeper into these requirements and discuss why they often become compliance stumbling blocks for organizations.

Top 10 CMMC Compliance Failures: A Deep Dive

Understanding the Top 10 Failures

A. Ensuring Data Safety and System Access

1. Implementing the Correct Cryptography: Protecting data requires the application of suitable cryptography. The failures in this area often stem from organizations not knowing the appropriate cryptographic methods to utilize or failing to stay updated with emerging cryptographic standards.

2. Utilizing Multi-Factor Authentication: This compliance requirement necessitates organizations to employ more than one method of verifying user identities during login. Failures frequently occur when organizations misinterpret what qualifies as a distinct authentication factor or fail to implement it across all relevant systems.

Regular Monitoring and Risk Assessment

3. Identifying and Rectifying System Issues: Organizations must proactively identify, report, and address system problems. Common failures arise when organizations lack an effective incident handling system or underestimate the importance of regular, comprehensive checks.

4. Conducting Regular Risk Assessments: This requirement necessitates organizations to regularly assess the risks associated with their operations and assets, starting with a clear understanding and definition of their system boundaries. Organizations need to conduct these assessments at predefined intervals and use well-established criteria for evaluating risks. Failures often occur when these assessments are not conducted with sufficient frequency or when all critical risk factors, including those that lie within the defined system boundaries, are not thoroughly considered.

5. System/Process Weaknesses: Periodic examination for system and process weaknesses is crucial for identifying potential security threats. Failures typically occur when these assessments aren’t performed frequently enough, don’t cover all necessary areas, or when identified issues aren’t appropriately addressed. This should also involve keeping an eye on newly published vulnerabilities that may impact the organization.

Maintaining Logs and Responding to Emergencies

6. Monitoring Log Events: Organizations must maintain and routinely examine detailed logs of system events. This primarily focuses on the configuration of the auditing system and processes. Failures often arise when organizations do not ensure logs are reported to system, fail to review them routinely, or neglect to respond appropriately based on the information recorded in the logs.

7. Implementing Alerts for Logging Issues: Organizations need to have alert mechanisms in place for when log processes fail. Failures often happen when there is a lack of an efficient alert system or when the system fails to detect all necessary incidents.

8. Reviewing Audit Records: Organizations are required to consistently review, analyze, and report on audit records. Failures often occur due to the absence of robust procedures for this task or misunderstanding of the audit records.

9. Testing Emergency Response Plans: Regular testing of emergency response plans is mandatory. Failures often occur when organizations do not conduct these tests regularly, fail to update the plans based on test results, or lack a comprehensive emergency plan to start with.

10. Documenting System Configuration: Organizations must establish, maintain, and update a comprehensive record of their system configuration. This involves documenting the baseline setup, keeping track of changes, and maintaining a detailed inventory of systems and software. Failures often happen when organizations do not keep records of the system setup or fail to update it when the system undergoes changes.

Top 5 Critical Compliance Failures

Deep Dive into the Top 5 OTS Requirements and Why They’re Often the Most Difficult to Meet – and How to Overcome Them

1. FIPS-Validated Cryptography:

FIPS-validated cryptography is often a challenge due to the complexity of the technology involved. Implementing validated cryptography across an organization’s systems requires a deep understanding of the standards and an ability to select and configure suitable cryptographic modules. Organizations may also struggle with staying abreast of updates to cryptographic standards and understanding how these changes impact their existing cryptographic implementations.

  • Remedy: Stay informed about the latest cryptography standards. Ensure that your IT team has the necessary training to implement and maintain FIPS-validated cryptography systems.

2. Multifactor Authentication:

Implementing multifactor authentication is technically challenging and can be seen as intrusive by end-users, leading to resistance. Organizations may also misunderstand the requirement and implement two instances of the same type of authentication (something you know), believing this satisfies the multifactor requirement.

  • Remedy: Invest in user-friendly MFA solutions and conduct regular training to ensure that all employees understand the importance of MFA and how to use it effectively.

3. Identify, Report, Correct System Flaws

Organizations often underestimate the resources necessary for robust system flaw management. Identification of system flaws requires regular vulnerability scanning and other proactive measures. Once identified, flaws must be assessed, prioritized, and corrected in a timely manner, all of which require substantial time and resources.

  • Remedy: Implement a comprehensive vulnerability management process. This should include regular vulnerability scanning, a system for prioritizing and addressing identified vulnerabilities, and regular reviews to ensure that the process is working effectively.

4. Periodically Assess Risk:

Conducting comprehensive, meaningful risk assessments is a skill that many organizations lack. Risk assessments should consider a broad range of potential risks, including both internal and external threats, and should be conducted regularly to account for changes in the risk environment.

  • Remedy: Develop a risk management framework that includes regular risk assessments. This should consider all relevant risks and be updated regularly to account for changes in the risk environment.

5. Scan for Vulnerabilities:

Scanning for vulnerabilities is often neglected due to resource constraints or a misunderstanding of its importance. Vulnerability scanning should be conducted across all systems and should include both automated scans and manual inspection. Scans should also be conducted on a regular basis, as new vulnerabilities can be introduced whenever systems are updated or changed.

  • Remedy: Make vulnerability scanning a priority. Implement both automated scanning solutions and regular manual inspections to ensure that all potential vulnerabilities are identified.

The Importance of Getting Professional Help for CMMC Compliance

Achieving CMMC compliance is a complex task that requires a deep understanding of the CMMC framework and cybersecurity best practices. It is a continuous process that requires regular attention and updates. This can be a substantial undertaking for many organizations, particularly smaller businesses without a large IT team.

Given these reasons, many organizations opt to engage professional help to achieve CMMC compliance.

This could potentially be a cybersecurity consultant who specializes in CMMC compliance. Alternatively, it could be a Managed Security Service Provider (MSSP) who can handle all aspects of your cybersecurity needs.

Such professional help can offer numerous benefits. Firstly, they provide a deep understanding of the CMMC framework, followed by knowledge of the latest cybersecurity threats and best practices. Furthermore, they possess the ability to customize a compliance strategy to fit your specific needs. By leveraging their expertise, you can, therefore, navigate the path to CMMC compliance more effectively and efficiently.


In our exploration of CMMC compliance, we identified the top 10 common failures, from implementing FIPS-validated cryptography to risk assessment, and vulnerability scanning. We also addressed the critical importance of thorough audit practices, regular testing of incident response plans, and maintaining baseline configurations. These are complex processes that require a strong understanding of the cybersecurity landscape and a proactive approach to risk management.

In order to navigate these challenges, we’ve outlined specific strategies and furthermore, we’ve underscored the importance of leveraging professional help. External cybersecurity experts, for instance, can provide deep insights and keep your organization updated with evolving standards and practices. As a consequence, they can guide you towards a path of compliance.

Moreover, CMMC compliance is not just a regulatory hurdle to overcome—it’s fundamentally a commitment to securing your operations and the nation’s defense infrastructure. Neglecting this duty can ultimately have grave implications, from reputational damage to potential contract losses.

Proactive commitment to CMMC compliance is the way forward. It’s an investment that not only mitigates risk but also elevates your standing in the eyes of clients, partners, and the Department of Defense. In the evolving digital landscape, staying ahead of cybersecurity threats is a continuous challenge but also a significant business opportunity. Your commitment to CMMC compliance is a testament to your dedication to maintaining the security that our digital world demands. Take the first step today, learn from the common failures, and stride confidently towards a robust cybersecurity future.

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