Top CMMC Compliance difficulties
- Defending Against Advanced Threats
Your CMMC journey is far from over if you achieve Level 3 compliance. It’s a significant achievement, but it’s due in part to the fact that Levels 4 and 5 require procedures that are several orders of magnitude more complex and difficult to apply. Importantly, the focus of these latter levels shifts away from CUI protection and toward advanced persistent threats (APT). APTs, as their name suggests, are one of the most challenging cybersecurity problems to solve, as they encompass all dangers offered by dedicated hackers and cybercriminals. These criminals make it a point to research your cyber defenses and keep an eye out for flaws they can exploit. As a result, you must be exceedingly cautious to stay ahead of them.
- Obtaining Complete Institutionalization
As previously said, one of the most difficult aspects of nist sp 800-171 is wrangling all of its procedures. However, implementing all 171 practices and fully fleshing out the 43 capabilities across the 17 domains isn’t enough to get to level 5. Furthermore, you must achieve process institutionalization, which is a measure of systematization across the entire organization. As you can see, the implementation of practices is made more difficult at each level, not only by the addition of additional (ever more complex) practices but also by the addition of additional process burdens. Fortunately, completing all of the essential practice and process milestones lead to the final challenge.
- Getting an Official Certificate
The final hurdle to achieving CMMC compliance is obtaining certification. Unlike some other frameworks, such as the NIST recommendations, self-assessment is not sufficient for compliance. Instead, you must be accredited by the OUSD(A&SCMMC )’s Accreditation Body and certified by an impartial and qualified observer, a Certified Third Party Assessment Organization (C3PAO). Not all C3PAOs function in the same way; some provide only certification services, with no advisory work to help you prepare for your assessment. As a result, collaborating with these companies may result in higher expenditures for repeat testing if something goes wrong.
- Completing the “Cyber Hygiene” project
The second problem involves achieving a goal: complete protection of “managed unclassified information” (CUI). Clause 252.204-7012 of the Defense Federal Acquisition Regulation Supplement (DFARS) specifies an important requirement for DoD contractors. It also corresponds to Level 3 compliance; this is where the real difficulty resides. Organizations do not require to implement all of the CMMC’s practices at once, unlike other frameworks (such as NIST SP 800-171).