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Top 10 CMMC Compliance Pitfalls and How to Avoid Them

by Danielle Barbour updated February 24, 2025 CMMC Compliance

Reading Time: 5 minutes

The Cybersecurity Maturity Model Certification (CMMC) represents a pivotal shift in how the Department of Defense (DoD) ensures the protection of sensitive defense information within its supply chain. While CMMC is designed to enhance the cybersecurity posture of the Defense Industrial Base (DIB), the path to certification can be fraught with challenges that unnecessarily delay compliance and certification.

In this post we’ll address the most common pitfalls that defense contractors encounter on their way to CMMC certification. By understanding and proactively addressing these challenges, defense contractors can streamline their path to compliance and maintain their ability to compete for and retain valuable DoD contracts.

Table of Contents

The Cost of Delay and Non-Compliance with CMMC

The consequences of delayed CMMC compliance or non-compliance can be severe and far-reaching.

First and foremost, contractors risk losing existing DoD contracts and becoming ineligible for new ones. The financial impact extends beyond lost revenue opportunities—non-compliant organizations may face hefty fines, legal penalties, and potential civil litigation if Controlled Unclassified Information (CUI) or Federal Contract Information (FCI) is compromised.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

Also, the reputational damage from non-compliance can be devastating. Once trust is broken with the DoD, rebuilding that relationship becomes exponentially more difficult. Non-compliant contractors may also face increased scrutiny in future assessments by third party assessor organizations (C3PAOs) and could be required to implement more stringent controls, leading to higher compliance costs.

Top 10 CMMC Pitfalls and Solutions

If CMMC compliance was easy, everyone would do it and it would call into question just how secure the DoD’s CUI and FCI really were. As a result, CMMC compliance must be rigorous. We’ve consolidated the ten most frequent hurdles defense contractors face when pursuing CMMC compliance. By knowing these challenges ahead of time, you can prepare for them and avoid any unnecessary delays in demonstrating compliance.

1. Inadequate Scoping of CUI Environment

Many organizations fail to properly identify and scope their CUI environment, either over-scoping (leading to unnecessary costs) or under-scoping (creating security gaps). This often occurs because contractors lack a clear understanding of what constitutes CUI or fail to map their information flows accurately.

To avoid this pitfall, begin with a thorough data classification exercise. Create detailed diagrams of how CUI flows through your organization, including all systems, personnel, and third-party interfaces that touch this information. Implement clear policies for CUI handling and ensure all stakeholders understand these requirements. Regular reviews of your scoping decisions will help maintain accuracy as your environment evolves.

2. Insufficient Documentation and Evidence Collection

A common mistake is waiting until just before the assessment to gather documentation and evidence. This reactive approach often reveals gaps in control implementation and leads to scrambling to create documentation retroactively.

Establish a proactive documentation strategy from the start. Implement a system for continuous evidence collection that aligns with CMMC assessment objectives. Create templates for required documentation and assign responsibility for maintaining them. Regular internal audits of your documentation will help identify gaps before they become issues during the official assessment.

3. Incomplete Asset Inventory Management

Defense contractors often struggle with maintaining an accurate and comprehensive inventory of assets that process, store, or transmit CUI. This fundamental gap undermines the effectiveness of other security controls and complicates risk management efforts.

Implement an automated asset discovery and management system. Establish procedures for regular inventory updates and reconciliation. Include both physical and virtual assets, and ensure your inventory tracks key information such as asset owners, location, and security requirements. Regular audits of your asset inventory will help maintain accuracy.

4. Inadequate Access Control Implementation

Many contractors struggle with implementing and maintaining proper access controls, often defaulting to overly permissive access rights or failing to implement the principle of least privilege consistently.

Develop a robust access control policy that clearly defines roles, responsibilities, and access requirements. Implement regular access reviews and establish procedures for quickly removing access when personnel changes occur. Utilize automated tools for access management and maintain detailed logs of all access changes.

Learn critical strategies to comply with the CMMC 2.0 Access Control requirement.

5. Poor Third-Party Risk Management

Organizations often overlook the security implications of their third-party relationships or fail to properly assess and monitor their suppliers’ security practices.

Establish a comprehensive third-party risk management program. Develop clear security requirements for vendors and partners, including specific CMMC-related obligations. Implement regular assessments of third-party security practices and maintain documentation of these evaluations.

6. Insufficient Incident Response Planning

Many organizations have inadequate incident response plans or fail to regularly test and update these plans. This can lead to chaos during actual security incidents and potential compliance violations.

Develop and maintain a comprehensive incident response plan that aligns with CMMC requirements. Conduct regular tabletop exercises and full-scale incident response drills. Update plans based on lessons learned and changing threat landscapes. Ensure all relevant personnel are trained on their roles and responsibilities.

Learn critical strategies to comply with the CMMC 2.0 Incident Response requirement.

7. Weak Configuration Management Practices

Organizations often struggle with maintaining secure configurations across their systems and fail to document changes properly. This leads to security gaps and compliance issues.

Implement a robust configuration management system that includes baseline configurations for all system components. Establish change control procedures that include security impact analyses. Regularly audit system configurations against security baselines and document all deviations.

Learn critical strategies to comply with the CMMC 2.0 Configuration Management requirement.

8. Inadequate Security Training Programs

Many contractors implement generic security training programs that don’t address specific CMMC requirements or fail to maintain regular training schedules.

Develop a comprehensive security awareness training program that specifically addresses CMMC requirements and CUI handling. Include role-specific training for personnel with special security responsibilities. Maintain detailed training records and implement regular refresher courses.

Learn critical strategies to comply with the CMMC 2.0 Awareness and Training requirement.

9. Poor Audit Log Management

Organizations often fail to properly configure, monitor, and maintain audit logs, limiting their ability to detect and investigate security incidents.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

Implement a centralized log management solution that captures all required audit events. Establish procedures for regular log review and analysis. Maintain adequate storage for historical logs and implement automated alerting for suspicious activities.

10. Incomplete Risk Assessment Processes

Many organizations conduct superficial risk assessments that don’t adequately identify and address security risks to their CUI environment.

Implement a comprehensive risk assessment process that aligns with CMMC requirements. Regularly update risk assessments based on changes in your environment and emerging threats. Maintain detailed documentation of risk decisions and mitigation strategies.

Learn critical strategies to comply with the CMMC 2.0 Risk Assessment requirement.

Accelerate CMMC Compliance with Kiteworks

While addressing these common pitfalls requires careful planning and execution, technology platforms can significantly accelerate your path to CMMC compliance. The Kiteworks Private Content Network is a particularly powerful solution, supporting nearly nearly 90% of CMMC 2.0 Level 2 requirements out of the box.

As a FedRAMP Moderate Authorized platform, Kiteworks provides defense contractors with pre-validated evidence of security controls, significantly streamlining the CMMC certification process. The platform offers comprehensive protection for CUI and FCI across multiple communication channels, including secure email, file sharing, web forms, and managed file transfer.

Key capabilities that address many of the pitfalls discussed above include:

Granular access controls and multi-factor authentication (MFA)
End-to-end encryption for all sensitive communications
Comprehensive audit logs and a CISO Dashboard for tracking all file activity
Centralized policy administration and enforcement
Automated security controls and compliance reporting
(Next-generation digital rights management) for secure collaboration

With Kiteworks, defense contractors can dramatically reduce the time and effort required to achieve CMMC compliance while ensuring robust protection of sensitive defense information.

Remember, CMMC compliance is not just about checking boxes – it’s about implementing effective security controls that protect our nation’s defense information. By understanding and avoiding these common pitfalls, and leveraging appropriate technology solutions, you can create a strong foundation for sustainable CMMC compliance.

To learn more about Kiteworks, schedule a custom demo today.

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