Why Your Company Should Get CMMC Maturity Level 2 Certified by a C3PAO ASAP
CMMC Has Arrived – Really
Today marks a major milestone for the Defense Industrial Base (DIB): the official rollout of Cybersecurity Maturity Model Certification (CMMC) requirements begins on November 10, 2025. From this point forward, all companies in the Defense Industrial Base (DIB) that receive, process, store, or transmit Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) are subjected to CMMC compliance.
Although the rollout will take three years to complete, DIB organizations should not be fooled by what appears to be a long runway. Instead, you should be racing to prepare for, execute, and successfully pass a CMMC Maturity Level 2 (ML2) assessment by an accredited CMMC Third-Party Assessment Organization (C3PAO). You have several compelling reasons to get your CMMC ML2 C3PAO certification as soon as possible.
Early certification not only ensures you’re ready for upcoming contract requirements; it also positions your company as a trusted, compliant partner within the DoD supply chain. CMMC isn’t coming – it’s here.
Contracting Officer Discretion
The CMMC rollout takes place in phases, with guidelines generally defining CMMC milestones during each one-year period. However, Department of Defense (DoD) contracting officers have discretion over which CMMC requirements to include in their contract solicitations.
For example, during the first phase, solicitations for contracts involving the exchange of Federal Contract Information (FCI) and/or Controlled Unclassified Information (CUI) will typically require all bidding parties to complete and submit a CMMC Maturity Level 1 (ML1) or Maturity Level 2 (ML2) self-assessment and self-attestation on the Supplier Performance Risk System (SPRS). In those cases, all bidders may bid as long as they self-certify that they meet all CMMC ML1 or ML2 practices.
That said, a DoD contracting officer may choose to include a CMMC Level 2 certification by a C3PAO as a requirement in any solicitation, even in Year 1 of the rollout. If you don’t already hold that certification, you may find yourself ineligible to bid on contracts that require it right now.
Prime Contractor Pressure and Preferred Supplier Status
DoD prime contractors understand two key things:
- The power of contracting officer discretion in determining which CMMC requirements apply to each solicitation, and
- The flow-down requirement, which mandates all bid team members, including subcontractors and suppliers, must demonstrate the appropriate level of CMMC compliance.
As a result, prime contractors have begun taking matters into their own hands, ahead of the official rollout schedule. Some prime contractors have already started requiring their suppliers to obtain CMMC ML2 certification through an accredited C3PAO before being considered for inclusion on bid teams.
The message is clear: no certification, no contract opportunity. Primes have decided not to take any chances; they’ll just find a different supplier.
On the flip side, if you already possess a CMMC ML2 C3PAO certification, you become an attractive option for prime contractors. Certification not only qualifies you for DoD solicitations that include CMMC ML1, CMMC ML2 self-assessment, and CMMC ML2 C3PAO assessment requirements; it also positions you as a preferred supplier. In competitive markets, that’s a competitive advantage over your peers.
Do the Math – Avoid the Bottleneck
When it comes to getting a CMMC ML2 C3PAO assessment, your timeline isn’t in your control. Yes, you can build a roadmap to determine when you will be prepared for an assessment, but that doesn’t guarantee your desired timing and C3PAO availability align. Here’s why.
The DoD estimates that approximately 80,000 DIB companies will need a CMMC Level 2 certification through a C3PAO. Yet today, fewer than 1,000 possess that certification. You must engage a C3PAO accredited by the Cyber AB to obtain that certification – and there are fewer than 100 accredited C3PAOs.
The average assessment may take upwards of a week to complete. Even assuming each accredited C3PAO has five assessment teams that can support clients simultaneously, that’s only 500 assessments per week or roughly 25,000 per year. While the Cyber AB will continue accrediting more C3PAOs, and more assessment teams will come online over time, the ramp-up will take time.
The math is simple: an assessment bottleneck is inevitable. The longer you wait to get in line, the greater the risk that you’ll miss contract opportunities. You may be waiting, but inclusion of CMMC in solicitations will not, and you may not be able to win contracts while you’re in line.
Accelerate Your C3PAO Assessment Readiness
Don’t hope your DoD contracts won’t be affected by CMMC for years to come. Don’t hope your prime contractors will grant exceptions. Don’t be complacent when it comes to your CMMC compliance journey.
Now is the time to move forward decisively. Exostar’s CMMC Ready Suite can help you get there. Start by identifying your current cybersecurity baseline, then map it against CMMC controls to pinpoint gaps and remediation priorities. Create and gather the necessary documentation and policies. Leverage Exostar’s managed service secure enclave for FCI and CUI that meets 96 of the 110 practices out-of-the-box. Calculate your compliance score accurately and submit it to SPRS.
With Exostar’s CMMC Ready Suite, you can accelerate every phase of preparation. So, when you are working with the assessors, you’re ready to pass and achieve certification.
If your business relies on DoD contracts, you can’t afford to wait another day. Schedule your CMMC Level 2 C3PAO assessment now and position your organization to win contracts.
