A Beginner's Guide to Writing CMMC-Required Policies

As the U.S. Department of Defense (DoD) continues to enforce cybersecurity requirements across its supply chain, CMMC 2.0 (Cybersecurity Maturity Model Certification) serves as the compliance program used to verify that contractors have implemented the required NIST SP 800-171 controls. At the heart of meeting these requirements is one important but often misunderstood element: policies.

If you’re new to CMMC—or policy writing in general—this guide will walk you through what’s required, what to include, and how to get started in a way that’s practical and manageable for your team.

What CMMC Requires: Policies vs. Procedures vs. Plans

Let’s start by clearing up some commonly confused terms:

• Policy – A high-level statement that outlines your organization’s rules, intentions, and governance. It answers the question: “What are we committed to doing?”
• Procedure – A step-by-step description of how a policy will be implemented. It answers: “How do we do it?”
• Plan – A strategy document used for organizing and coordinating efforts. Examples include incident response plans or contingency plans.

In CMMC 2.0—particularly at Level 2, which aligns with NIST SP 800-171—you are expected to have documented policies for every relevant control family. These policies serve as evidence that your organization understands and governs the implementation of cybersecurity practices.

Core Policies You Need to Address

CMMC Level 2 requires documentation across 14 domains, each representing a group of related security controls. That means you’ll need at least one policy per domain and, in some cases, more.

Here’s a breakdown of standard policies aligned with each domain:

CMMC Domain	Required Policy Example
Access Control (AC)	Access Control Policy
Audit and Accountability (AU)	Audit Logging & Monitoring Policy
Awareness and Training (AT)	Security Awareness Training Policy
Configuration Management (CM)	Configuration Management Policy
Identification and Authentication (IA)	Identity and Access Policy
Incident Response (IR)	Incident Response Policy
Maintenance (MA)	System Maintenance Policy
Media Protection (MP)	Media Handling & Disposal Policy
Personnel Security (PS)	Personnel Security Policy
Physical Protection (PE)	Physical Security Policy
Risk Management (RM)	Risk Management Policy
Security Assessment (CA)	Security Assessment & Audit Policy
System and Communications Protection (SC)	Network & Data Protection Policy
System and Information Integrity (SI)	System Integrity & Malware Protection Policy

You may already have some of these policies in place—especially if your organization has followed NIST 800-171. If not, now is the time to build them.

How to Write a Policy: Structure and Best Practices

Writing policies doesn’t need to be overwhelming. Each policy should follow a clear, repeatable format. Here’s a basic template:

1. Purpose – Why this policy exists and what it aims to achieve
2. Scope – What systems, people, and operations are affected
3. Roles and Responsibilities – Who owns the policy, and who must follow it
4. Policy Statement – The actual rules or requirements your organization enforces
5. Enforcement – Consequences for non-compliance (internally)
6. Review and Maintenance – How often will the policy be reviewed, and by whom

Tips:

• Keep your language simple and direct—this isn’t a legal copy.
• Avoid over-promising. Only commit to what your organization can support.
• Use version control and note the last review/update date.

Common Mistakes to Avoid

Many organizations fall into the trap of creating policies to “check the box.” However, ineffective or outdated policies can be a red flag to assessors. Here are some common missteps:

• Using templates without customization – Generic policies that don’t reflect your actual environment or processes won’t pass muster.
• Lacking enforcement or accountability – Policies must name responsible parties and outline how compliance is measured.
• Forgetting to communicate and implement – A policy no one knows about is functionally useless.
• Omitting links to procedures – Without procedures or references to them, it’s unclear how the policy is executed.

Keeping It Manageable: A Phased Approach

If the complete list of policies feels intimidating, don’t try to do everything at once. Instead:

• Prioritize high-risk or high-visibility areas, such as access control, incident response, and system protection.
• Review existing documentation to identify what you already have or can repurpose.
• Start small—create basic, one-page policies and refine them over time.
• Link policies directly to your System Security Plan (SSP) to streamline audit readiness.

Final Thoughts: Policies as a Compliance Foundation 

Strong policies are the backbone of your cybersecurity compliance program. They demonstrate to auditors—and, more importantly, your team—that your organization takes security seriously and is committed to maintaining a compliant environment. 

Start now, keep it simple, and build a set of policies that reflect how your organization operates. Not only will it help you prepare for CMMC assessments, but it will also strengthen your cybersecurity posture across the board. 

Learn more about how Exostar’s PolicyPro can help you create policies that are compliant.