Understanding the CMMC Audit
If your business is pursuing or already holding Department of Defense (DoD) contracts, you know that cybersecurity compliance is quickly becoming a prerequisite for doing business. The ultimate step in proving your organization is secure and ready for sensitive work is undergoing the formal Cybersecurity Maturity Model Certification (CMMC) audit.
While the audit process may seem complex, especially with evolving federal requirements, the right preparation and understanding can turn it into a strategic engagement rather than a stressful inspection.
Here is what defense contractors need to know about preparing for, navigating, and succeeding in the CMMC audit process.
Who is Your Assessor and What is the Scope?
For most organizations handling Controlled Unclassified Information (CUI), the CMMC Level 2 audit focuses on proving the implementation of the 110 security controls mandated by NIST SP 800-171.
• Audit Conductors: CMMC Level 2 audits are conducted by accredited Certified Third-Party Assessment Organizations (C3PAOs). If your organization is pursuing the highest level, CMMC Level 3, the assessment is conducted by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
• The Assessment Team: Your audit team will include a Lead Assessor who determines the methods, a Secondary Assessor who supports the evaluation, and a Quality Assurance Reviewer who ensures correct administration and documentation.
• Defining Scope: Before the audit, you must clearly define which parts of your organization are "in scope" for evaluation. This includes categorizing assets such as: CUI Assets, Security Protection Assets, Contractor Risk Managed Assets, and Specialized Assets (like IoT or GFE).
The Three Core Assessment Methods
CMMC assessors do not rely on documentation alone; they actively verify that your security controls are truly implemented. They use a combination of three core methods to evaluate your readiness:
1. Examine: This involves the review of finalized documentation, such as policies, training materials, procedures, and network diagrams.
2. Interview: Assessors will conduct conversations with staff across the organization to confirm their understanding and execution of security practices.
3. Test: This method involves the real-time validation of technical controls to verify that they are operational and effective.
Successful audit preparation requires you to ensure all practices for your target level are documented, implemented, and supported by evidence.
Audit Outcomes: Final vs. Conditional Certification
Once the audit concludes, the assessment team files a report into the DoD’s eMASS system. Every CMMC practice will receive one of three ratings: Met, Unmet, or Not Applicable.
The result determines the type of certification you receive:
Certification Type
Requirements
Next Steps
Final Level 2
All 110 controls and 320 objectives must be Met.
Certification is valid for three years, requiring annual affirmations.
Conditional Level 2
Requires six key controls to be Met, plus an overall score of ≥80%.
Unmet controls are placed in a Plan of Action & Milestones (POA&M).
Critical POA&M Restrictions: If you receive a Conditional Level 2, you are given only 180 days to remediate the controls listed in your POA&M and pass a close-out assessment. Furthermore, CMMC Level 2 imposes a strict limitation: all high-value 3- and 5-point controls must be fully implemented before assessment; only certain 1-point controls are permitted to be covered by a POA&M.
Achieving CMMC certification is not the end of the journey; it is a signal to federal agencies that you are reliable and secure. Even after certification, the DoD may conduct independent reviews known as DCMA DIBCAC Investigations, which supersede your CMMC audit.
The Bottom Line: Treat the CMMC audit as a strategic imperative. Ensure your scoping is clearly defined, documentation is complete, and staff is trained and prepared. A well-prepared audit process positions your business to win—and retain—defense contracts