According to a recent GAO report (GAO-22-104844), the implementation of the Cybersecurity Maturity Model Certification (CMMC) program has introduced significant compliance costs for Department of Defense (DoD) contractors. One of the most critical decisions a small defense contractor must make is determining which CMMC level to pursue, as each level has distinct requirements and associated costs.
~27%
— added cost of achieving CMMC Level 3 compliance over Level 1 for small contractors (Source: GAO-22-104844)
Breaking Down CMMC Compliance Costs
A detailed analysis of the costs associated with each CMMC level reveals that Level 3 compliance requires significantly more investment than Level 1. This is primarily due to the need for more advanced security controls, such as multi-factor authentication and regular security audits. For small contractors with limited resources, the added expense of achieving Level 3 compliance can be a substantial burden.
The decision to pursue CMMC Level 3 compliance should be based on a thorough assessment of the potential benefits and costs. Contractors must carefully weigh the value of competing for contracts that require Level 3 compliance against the significant upfront investment required to achieve this level of maturity.
“Small contractors must carefully consider the costs and benefits of pursuing CMMC Level 3 compliance, as the added expense can be a significant burden for companies with limited resources.”
— GovCon IC (The Government Contractor Intelligence Center) analysis
Actionable Takeaways for Small Contractors
To navigate the complexities of CMMC compliance, small contractors should prioritize the following steps: conducting a thorough gap analysis to determine current security control maturity, developing a comprehensive compliance plan, and establishing a budget for the necessary investments in security controls and personnel training.
- Conduct a thorough gap analysis to determine current security control maturity
- Develop a comprehensive compliance plan
- Establish a budget for the necessary investments in security controls and personnel training
What to Do This Week
Review your company’s current security control maturity and develop a preliminary compliance plan to achieve the desired CMMC level. This will help you better understand the costs and benefits associated with each level and make an informed decision about which level to pursue.
In conclusion, achieving CMMC Level 3 compliance can be a costly endeavor for small defense contractors. By carefully considering the costs and benefits and developing a comprehensive compliance plan, contractors can make informed decisions about which CMMC level to pursue and ensure they are well-positioned to compete for DoD contracts.


