CMMC compliance is no longer just a cybersecurity requirement. It’s a prerequisite for doing business with the Department of Defense (DoD), also known as the Department of War.
As the Cybersecurity Maturity Model Certification (CMMC) is phased into contracts, noncompliance can prevent contractors from new awards, delay awards, or remove them from prime contractor supply chains altogether.
Eligibility risk does not begin at assessment. It often starts earlier with inaccurate Supplier Performance Risk System (SPRS) scores, unsupported self-assessments, or incomplete implementation of National Institute of Standards and Technology Special Publication 800-171 (NIST SP 800-171) controls.
Understanding how CMMC noncompliance affects contract eligibility is critical for defense contractors that want to compete and remain viable.
Dig deeper below to see where eligibility is most commonly lost and how to reduce that risk.
CMMC is enforced at the contract level. Once a required CMMC level is included in a solicitation or award, compliance becomes mandatory.
This means:
Unlike earlier self-attestation models, CMMC requires evidence-backed implementation of security controls. Intent, future plans, or informal assurances are not sufficient.
For contractors handling Controlled Unclassified Information (CUI), this shifts cybersecurity from internal best practice to external eligibility requirement.
Most eligibility issues stem from misunderstandings, not malicious intent.
SPRS scores are often reviewed before certification is required.
Problems arise when:
An inflated or outdated SPRS score can flag an organization as high risk and raise False Claims Act concerns.
CMMC Level 2 self-assessment is the exception, not the rule.
Self-assessment is only allowed when:
The DoD anticipates more than 95% of defense companies handling CUI will need a third-party assessment. Contractors that assume otherwise risk immediate ineligibility.
CMMC requires full implementation of all applicable NIST SP 800-171 controls.
Common gaps include:
Policies alone do not satisfy assessment objectives. Controls must be implemented, operating, and supported by evidence.
If you answer “no” or “not sure” to any of the questions below, your contract eligibility may already be at risk.
ISI Insight: A quick way to determine whether or not a Level 2 (Self) certification will be allowed is by looking at contract awarded to your prime. If your prime has to be Level 2 (C3PAO) certified, a third-party assessment will be required.
Eligibility is not decided at audit time. It is often decided earlier during bid reviews, supply chain screening, and contract flow-downs.
Prime contractors are under increasing pressure to manage supply chain risk.
As a result, many primes now require subcontractors to demonstrate CMMC readiness before work begins.
This often includes:
Even if the DoD has not yet required certification, primes may limit subcontractor participation to reduce their own exposure.
CMMC noncompliance can quietly remove contractors from opportunities without formal notice.
CMMC readiness is not a short-term effort.
Most organizations require time to:
Waiting until a solicitation is released often means missing the eligibility window. By the time certification is required, preparation time is gone.
Contractors that stay eligible treat CMMC as a business requirement, not a last-minute compliance task.
Key actions include:
CMMC compliance is not about passing an audit. It is about maintaining access to DoD work.
Not always. However, noncompliance can prevent contract renewals, block new task orders, and disqualify your organization from recompetes. Eligibility is often evaluated at award and option periods, not just during active performance.
Only if the contract explicitly allows POA&Ms. Even then, POA&Ms do not replace required control implementation and must be tied to documented remediation activities with defined timelines. If a POA&M is allowed, you will be given “Conditional Certification” which is only valid for 180 days.
Yes. Many prime contractors already screen subcontractors based on CMMC readiness, even when certification is not yet contractually required. Additionally, these requirements could be added to option years in your contracts.
No. Prime contractors cannot waive DoD-mandated CMMC requirements once they are included or flowed down in a contract.
No. Tools can support compliance, but CMMC requires implemented, operating controls supported by policies, procedures, and evidence.
Inaccurate SPRS scores can raise red flags with the DoD or primes and may create False Claims Act exposure if unsupported by documentation and evidence.
Most organizations require several months to complete gap assessments, implement controls, update documentation, and prepare for assessment.
Assume third-party assessment will be required, maintain accurate documentation, and treat CMMC as an ongoing business requirement. Working with an expert partner can help you expedite your compliance journey and stay ahead of the ever-evolving regulations.