Compliance in defense contracting has never been more closely watched, and organizations are finding that meeting security standards goes beyond checking boxes. It is about demonstrating maturity, accountability, and readiness to safeguard controlled unclassified information. For those pursuing CMMC level 2 compliance, there are several distinct assessment paths that set the direction for how readiness is validated and upheld.
Self-Assessment path for non-prioritized CUI contracts
Organizations that deal with non-prioritized controlled unclassified information are permitted to complete a self-assessment rather than undergo outside validation. This path requires businesses to measure their practices against the CMMC level 2 requirements and determine if controls are being implemented as intended. The process must be honest, consistent, and documented in a way that stands up to scrutiny if reviewed later.
The self-assessment path benefits contractors handling less sensitive data, allowing them to focus on operational improvements without the expense of a third-party review. However, even under this streamlined approach, teams must evaluate all applicable practices in detail. Failure to assess thoroughly could result in gaps that undermine future bids or trigger compliance concerns.
Third-Party Assessment path via a C3PAO
For contracts labeled as prioritized, organizations must undergo a full third-party assessment carried out by a certified third-party assessment organization, known as a C3PAO. This independent review serves as the government’s assurance that contractors are not just self-reporting but also meeting defined standards. The assessment includes detailed testing, document verification, and validation of implemented security measures.
Because the C3PAO is accountable for delivering an unbiased evaluation, contractors must prepare for a deeper level of scrutiny than in a self-assessment. This includes demonstrating that security controls are actively working in the production environment. Achieving CMMC level 2 compliance under this path proves that the organization has more than policies on paper—it shows actual performance of controls aligned with federal expectations.
Annual senior-official affirmation route
Each year, senior officials in contracting organizations must provide a signed affirmation that security practices remain consistent with the prior assessment. This affirmation reinforces accountability at the leadership level, ensuring executives stay engaged in security matters and not delegate compliance entirely to IT teams. It formalizes the responsibility of leadership to maintain an accurate picture of their organization’s security posture.
The affirmation is not a casual statement—it must align with the organization’s documented assessment and evidence. If practices have slipped, the senior official risks reputational and contractual consequences. In this way, the requirement maintains an ongoing cycle of responsibility and discourages a “one and done” attitude toward CMMC compliance requirements.
Formal submission into the SPRS registry
All assessment results, whether completed internally or by a C3PAO, must be formally submitted into the Supplier Performance Risk System, known as SPRS. This database functions as a government-wide clearinghouse where contracting officers review whether vendors meet requirements before awarding contracts. Submission into SPRS is a mandatory step that provides transparency across the defense supply chain.
Contractors must ensure the data they enter into SPRS is accurate and current. Incorrect or incomplete reporting could lead to eligibility issues or worse, claims of false certification. Because of this, many organizations work with a CMMC RPO to verify that submissions align with assessment outcomes and remain defensible during audits.
Full evaluation of all 110 NIST SP 800-171 controls
At the heart of CMMC level 2 requirements is the full evaluation of all 110 controls specified under NIST SP 800-171. This is not a selective review but a comprehensive examination of how each requirement is implemented across the organization. Controls span multiple domains, from access management and incident response to encryption and system monitoring.
The evaluation process ensures that contractors cannot pick and choose which practices to follow. Instead, compliance reflects a full-spectrum security posture. Understanding how to apply each of the 110 controls in operational environments is one of the most technical aspects of the process, requiring detailed documentation and continuous monitoring to maintain compliance status.
Remediation and POA&M closure within 180 days
If deficiencies are identified during an assessment, organizations may be allowed to document them in a Plan of Actions and Milestones (POA&M). However, these items must be resolved within 180 days to retain compliance eligibility. This timeline creates urgency and prevents long-term gaps from persisting in critical areas of security.
Closing POA&M items demands disciplined project management. Technical teams must prioritize fixes, track progress, and produce evidence of resolution. The 180-day window is designed to keep security risks from becoming permanent, reflecting the government’s intent that organizations actively strengthen their defenses rather than rely on promises of future action.
Triennial reassessment for prioritized contracts
Contracts involving prioritized controlled unclassified information require triennial reassessment by a C3PAO. This means every three years, organizations must undergo a fresh review to confirm their compliance posture has not diminished. Regular reassessments reinforce the idea that compliance is a sustained state, not a one-time event.
For contractors, this cycle ensures ongoing investment in security programs. Documentation, policies, and technical safeguards must be maintained with the knowledge that auditors will return within a fixed timeframe. Those who neglect upkeep will find reassessments more challenging, with higher risks of failing to meet CMMC level 2 compliance expectations.
Evidence-based interviews, testing, and documentation review
Assessments are not limited to paperwork. They include direct interviews with staff, technical testing of systems, and comprehensive documentation reviews. These evidence-based methods give assessors confidence that practices are not theoretical but are operationally in place. The rigor of these activities separates CMMC level 2 compliance from less demanding frameworks like CMMC level 1 requirements.
Organizations preparing for these reviews must be ready to demonstrate not just policies but day-to-day execution. Staff should understand their security responsibilities, technical configurations should meet standards, and documentation should be consistent with actual practices. This evidence-based model is designed to provide assurance that contractors can reliably protect sensitive defense information