ISI Insights

10 CMMC Red Flags That Signal You’re Not Ready

Written by ISI | Jan 22, 2026 1:56:16 AM

EXECUTIVE BRIEF 

If you plan to bid on Department of Defense (DoD) (also known as the Department of War) contracts that include Cybersecurity Maturity Model Certification (CMMC) requirements, CMMC readiness is no longer optional. 

Many defense contractors believe they are “close enough” to compliant. In reality, small gaps in documentation, scope, or control implementation can signal major readiness issues during an assessment. 

If any of these red flags sound familiar, it may be time to reassess your approach before contracts, primes, or assessors do it for you. 

Dig deeper below to learn 10 clear red flags that often indicate an organization is not ready for a CMMC assessment, even if leadership believes otherwise.

1. You Do Not Have a Current System Security Plan (SSP)

A SSP is the foundation of CMMC Level 2. 

Red flag indicators: 

  • Your SSP has not been updated in the last year 
  • The SSP does not reflect your current environment 
  • Controls are described generically instead of how they are implemented 

An outdated or incomplete SSP almost guarantees assessment findings. Lacking an SSP entirely means you are likely not to be assessed.

2. Your Supplier Performance Risk System (SPRS) Score Is Missing or Inaccurate

The SPRS score reflects alignment with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Rev 2. 

Red flag indicators: 

  • No score has been submitted 
  • The score does not match your actual implementation 
  • There is no evidence backing the score 

Inaccurate SPRS reporting creates both compliance and legal risk.

3. Plans of Action and Milestones (POA&Ms) Are Being Used as Placeholders 

POA&Ms are allowed, but they are limited. 

Red flag indicators: 

  • Critical controls are deferred into POA&Ms 
  • POA&Ms lack owners, dates, or funding 
  • POA&Ms are being used to avoid remediation 

CMMC does not allow POA&Ms to replace required implementation at assessment time. 

ISI Insight: If you have controls worth three or five points on your POA&M, you likely will not pass your Level 2 assessment.

4. You Cannot Clearly Define What Is in Scope 

If you cannot explain what systems process, store, or transmit Controlled Unclassified Information (CUI), you are not ready. 

Red flag indicators: 

  • No documented CUI data flow 
  • Entire networks are marked in scope “to be safe” 
  • Specialized assets are undocumented 

Poor scoping drives cost, risk, and assessment failure.

5. Security Is Treated as an IT Problem Only

CMMC is an organizational requirement, not an IT project. 

Red flag indicators: 

  • Leadership is not involved 
  • Policies exist but are not enforced 
  • Employees do not receive proper, or regular, training sessions 
  • Business units are unaware of requirements 

Assessors look for governance, accountability, and leadership support.

6. You Rely on Tools Instead of Implementation

Compliance software helps manage compliance. It does not create it. 

Red flag indicators: 

  • “The platform does that” is the main explanation 
  • Lacking a documented Shared Responsibility Matrix 
  • Controls are documented but not operational 
  • Evidence only exists inside dashboards 

Assessments focus on real-world implementation, not screenshots.

7. You Have Never Performed a True Gap Assessment

Many organizations skip formal gap assessments and go straight to remediation. 

Red flag indicators: 

  • No mapping to assessment objectives 
  • No prioritization of high-weight controls 
  • Assumptions instead of validation 

A proper gap assessment drives readiness and budgeting.

8. You Cannot Produce Evidence on Demand

Evidence must be available, accurate, and repeatable. 

Red flag indicators: 

  • Evidence is scattered across systems 
  • Staff are unsure where artifacts live 
  • Evidence does not align with SSP descriptions 

If evidence takes weeks to find, your assessment will not go well.

9. You Are Unsure Whether You Need a Self-Assessment or Third-Party Assessment

Most contractors will require a Certified Third-Party Assessment Organization (C3PAO) assessment. 

Red flag indicators: 

  • Assuming self-assessment applies by default 
  • No contract language review 
  • Conflicting guidance from internal teams 

The contract determines the assessment path, not preference.

10. You Are “Working Toward” Compliance Without a Deadline

Intent does not equal compliance. 

Red flag indicators: 

  • No funded remediation plan 
  • No internal milestones 
  • No leadership accountability 

CMMC requirements apply at time of award, not when convenient.

 

FAQs 

How do we know if we are ready for a CMMC assessment? 

Readiness means more than documentation. You should be able to demonstrate implemented controls, produce evidence aligned to assessment objectives, explain your scope clearly, and show that leadership understands and supports the program. If your team struggles to answer basic assessor-style questions internally, more preparation and external support is needed. 

Can we still win contracts if we have gaps but a plan to fix them? 

Only in limited cases. The CMMC 32 CFR rule lays out which controls are allowed to be on a POA&M and to what extent. If you meet these requirements, your business will receive a Conditional Certification which will allow you to accept contract awards (if given). However, it is only good for 180 days and you will need to undergo another assessment or risk being kicked off the contract. Relying on future remediation creates real contract risk. 

How important is the System Security Plan during an assessment?

The SSP drives the entire assessment. Assessors use it to understand your environment, validate control implementation, and guide evidence requests. If the SSP is inaccurate or vague, it increases findings even when controls exist. 

Does using a managed service provider or compliance tool reduce our responsibility?

Sometimes, but only in a limited and well-documented way. If your organization operates entirely in its own environment, responsibility for all CMMC Level 2 controls remains with the contractor. When using a CMMC Level 2 certified provider or enclave, you may inherit a portion of their certified controls, which can reduce assessment scope. However, inheritance is capped and typically does not exceed about 80 percent, since organizational, governance, and personnel-related controls always remain the contractor’s responsibility. A Shared Responsibility Matrix is essential to clearly document what is inherited versus what is locally implemented. Even when controls are inherited, assessors hold your organization accountable for outcomes and evidence. 

What is the fastest way to reduce readiness risk? 

Start with a scoped gap assessment aligned to NIST SP 800-171 assessment objectives. Update the SSP, validate evidence, confirm your assessment path, and prioritize remediation of high-impact controls. Speed comes from focus, not shortcuts. Bringing in an expert partner like ISI can help further expedite your compliance journey. 

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