When CMMC 2.0 was announced on November 11th, 2021 most DoD contractors released sighs of relief. CMMC 2.0 addressed many of the industry's concerns around the original CMMC. These initial concerns included high costs for small businesses, complex security requirements, and potential conflicts of interest.
What is new with CMMC 2.0?
There are now only three CMMC levels in total
The old CMMC model level 2 and 4 have been eliminated
Security requirements or “practices” that were unique to the old CMMC model have been limited
Maturity processes (e.g, AC.2.999) from the old CMMC model are gone
The new CMMC levels are level 1 “Foundational”, level 2 “Advanced”, and level 3 “Expert”
Companies with CMMC level 1 requirements will no longer require a third party assessment, instead they will be required to complete an annual self-assessment
Companies with CMMC level 2 requirements who have “critical national security information” will undergo triennial third party self-assessments or annual self-assessments for “select programs”
Companies with CMMC level 3 requirements will undergo triennial government led assessments
CMMC level 2 requirements now align directly with NIST SP 800-171
CMMC level 3 will be based on a subset of NIST SP 800-172 requirements
What CMMC 2.0 Likely Means for Contractors
Reduced costs because a third party assessment may not be required for as many contractors
Reduced costs because the number of security requirements have been reduced
Security requirements are easier to meet as “maturity levels” have been eliminated from CMMC
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