Preparing Your Team for CMMC: Key Roles and Responsibilities

What’s New (Updated Roles, Accountability & Assessment Readiness)

This blog has been updated to reflect the CMMC Final Rule (32 CFR Part 170), now fully enforceable as of November 10, 2025. Organizations must have clearly defined roles, documented responsibilities, and evidence-backed governance in place to meet Level 1 or Level 2 requirements at contract award. Any references to future CMMC implementation have been removed or updated to reflect active enforcement.

Understanding Your Team’s Role in CMMC Compliance

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is a mandatory framework designed to enhance the cybersecurity posture of contractors and suppliers in the Defense Industrial Base (DIB). With increasing cyber threats targeting sensitive defense-related information, the Department of Defense (DoD) now enforces these requirements under the CMMC Final Rule, making proper security practices and role accountability mandatory for contract eligibility.

But where do you start?

One of the most common pitfalls in CMMC compliance is unclear roles and responsibilities within an organization. Companies risk falling behind deadlines, failing assessments, and losing valuable contracts without a structured approach.

This blog will walk you through:

• The key roles needed for CMMC compliance
• How to assign responsibilities effectively
• Common challenges teams face and how to overcome them
• Best practices for streamlining compliance efforts

Why Clearly Defined Roles Matter in CMMC Compliance

Cybersecurity isn’t just an IT concern—it’s an organizational-wide effort. From executive leadership to frontline employees, everyone is responsible for securing Controlled Unclassified Information (CUI) and meeting NIST SP 800-171 requirements.

Without defined roles, organizations often face:

• Confusion – Who is responsible for what? Lack of clarity leads to missed tasks, audit failures, and compliance gaps.
• Inefficiency – Overlapping responsibilities or redundant efforts waste time and resources.
• Increased risk – Cybersecurity gaps caused by a lack of accountability can result in breaches, penalties, or contract loss.

Businesses can create an efficient and audit-ready compliance process by assigning clear roles and implementing structured compliance workflows.

Expanded Key Roles in a CMMC Compliance Team

To ensure success, organizations should define critical roles in their compliance framework:

Executive Leadership / Compliance Sponsor

Who: C-suite executives (CIO, CISO, CEO) or senior management.

Responsibilities:

• Define and endorse company-wide CMMC policies.
• Evaluate the business impact of CMMC compliance versus market opportunity.
• Provide strategic and budgetary support.
• Designate a Compliance Officer or CMMC Program Manager.

Compliance efforts often stall without executive buy-in due to resource limitations or lack of priority.

Compliance Manager / CMMC Program Lead

Who: A dedicated compliance officer, risk manager, or cybersecurity lead.

Responsibilities:

• Liaise with C3PAOs and manage external audits.
• Oversee POA&M development and SPRS score accuracy.
• Align organizational controls with NIST SP 800-171.
• Monitor continuous improvement and certification maintenance.

A Compliance Manager is the backbone of CMMC readiness—ensuring deadlines are met, and compliance remains a continuous effort.

Legal & Data Protection Officer (DPO)

Responsibilities:

• Ensure DFARS 252.204-7012 and FAR compliance.
• Identify and classify CUI and FCI.
• Mitigate legal risks related to cybersecurity contracts.
• Align data protection with contractual and federal obligations.

IT & Security Team

Who: CISO, ISSO, IT Director, Security Engineers

Responsibilities:

• Implement and monitor security controls (access, encryption, endpoint security).
• Ensure FedRAMP Moderate compliance for CSPs handling CUI.
• Conduct patch management and enforce secure configurations.
• Lead incident response and risk management processes

IT teams provide the technical backbone of compliance—ensuring secure systems, networks, and access management.

Risk Manager & Internal Auditor

Responsibilities:

• Conduct gap assessments and develop POA&Ms.
• Monitor and document risk continuously.
• Support readiness assessments and external audit preparation.

Procurement & Vendor Management

Responsibilities:

• Ensure vendor compliance and flow-down clause enforcement.
• Conduct contract reviews and manage third-party cybersecurity risks.
• Work with legal and compliance on supply chain risk management (SCRM).

HR & Training Coordinators

Who: HR managers, compliance trainers, or security awareness leads.

Responsibilities:

• Develop and deliver security awareness and role-based training.
• Conduct phishing simulations and monitor training completion.
• Promote a culture of cybersecurity vigilance.

Human error is one of the biggest causes of compliance failures. A strong training program can reduce security risks and strengthen organizational awareness.

Operations & Business Unit Leads

Who: Department heads responsible for handling CUI (engineering, procurement, supply chain, etc.).

Responsibilities:

• Ensure security policies are followed within their teams.
• Identify compliance gaps in everyday workflows.
• Collaborate with IT and compliance teams to implement security improvements.
• Provide documentation for audit preparation.
• Operational leaders help bridge the gap between cybersecurity policies and real-world business processes.

Third-Party Vendors & Consultants

Who:

• C3PAO: Conducts Level 2/3 assessments.
• CCP/CCA: Certified professionals responsible for guidance and audits.
• RPOs: Help prepare for certification, but do not assess.
• ESPs/MSPs/MSSPs: Support IT and security implementation.

Responsibilities:

• Provide expert guidance and remediation plans.
• Support SSP/POA&M documentation.
• Offer infrastructure, staff augmentation, and assessment support.

Many organizations lack the internal resources for CMMC compliance and rely on trusted partners to navigate complex requirements.

Regulatory Update Under the Final Rule

CMMC requirements are now enforceable as of November 10, 2025. Level 1 and Level 2 requirements must be met at contract award, POA&Ms are limited and time-bound, SPRS accuracy is mandatory, and Cloud Service Providers handling CUI must meet FedRAMP Moderate (or equivalent) requirements.

How Sikich’s STARS Program Simplifies CMMC Compliance

Sikich’s Scope, Train, Assess, Remediate & Support (STARS) Program helps organizations achieve compliance efficiently through a structured, phased approach.

The STARS Program Helps You:

• Eliminate uncertainty with expert-led guidance.
• Reduce risk via proactive assessments.
• Accelerate documentation and security control development.
• Maintain compliance through ongoing monitoring.

The STARS Five-Step Framework:

1. Scope: Define the compliance boundary and assign key roles.
2. Train: Ensure all teams are educated on CMMC duties.
3. Assess: Conduct internal readiness assessments.
4. Remediate: Close gaps via detailed POA&Ms and control enhancements.
5. Support: Maintain certification with continuous oversight.

Organizations using STARS reduce time-to-certification by over three months compared to manual or siloed approaches.

Best Practices for Preparing Your Team for CMMC

• Start Early: Compliance isn’t a one-time effort—begin assessments and role assignments now to stay ahead of deadlines.
• Define Clear Roles & Responsibilities: Assign accountability at every level—from leadership to frontline employees.
• Invest in Training: Regular security awareness programs ensure that employees stay compliant and alert to risks.
• Automate Documentation & Monitoring: Reduce errors and improve efficiency by using compliance management platforms.
• Conduct Internal Audits: Routine compliance check-ins help catch gaps before formal CMMC assessments.

Conclusion

CMMC 2.0 compliance is a team effort—and success starts with clearly defined roles, structured workflows, and expert guidance. Organizations that take a proactive approach will achieve compliance faster, reduce risk, and strengthen cybersecurity posture.

Now that CMMC enforcement is active, organizations must assess their team’s readiness, confirm role accountability, and ensure evidence supports all CMMC level requirements outlined in upcoming solicitations.

If your organization lacks clearly defined compliance roles, or if responsibilities are fragmented across teams, now is the time to create structure and accountability. Explore tools that help organizations centralize documentation, streamline workflows, and stay aligned with CMMC requirements under the Final Rule.

Here’s What You Need to Do Now

To comply with the Final Rule, organizations should verify they have assigned clear ownership for SSP development, evidence gathering, SPRS score accuracy, POA&M completion, incident response coordination, and subcontractor oversight. Map each CMMC practice to a responsible leader or team, ensure all staff with access to CUI receive role-based training, and confirm that policies, procedures, and workflows are being followed consistently. Use the CMMC Levels Quiz to confirm your required level and identify any gaps in team readiness before contract award.