When defense contractors inquire about timelines for CMMC, the answers they receive are often vague and unhelpful for organizational planning. Some consultants say that it takes three months to get certified; others warn that it's a year or more. The reality is that the certification takes more or less time based upon a company's current situation and investment in requisite action to fill those gaps. However, there is a reasonable timeline framework to create consistency in planning.
Assess Current Situation
Before anything else, an organization needs to ascertain its current situation. This gap assessment, with few contractors assuming they're more prepared than others believe, generally takes two to four weeks for the average organization. This process involves looking at what a company is currently doing for security measures compared to what CMMC requires and what additional steps need to be taken.
Smaller organizations, for example, who have many of their IT issues in one place, may be able to accomplish this faster, while larger organizations, with several physical and technical locations, may take longer.
Here's the thing, this initial phase often reveals surprises. A company might assume they're 80% compliant only to discover they're closer to 50%. The assessment uncovers issues with documentation, access controls, incident response procedures, and dozens of other requirements that weren't on anyone's radar. Getting professional help with cmmc compliance requirements during this stage prevents costly mistakes later when fixing problems becomes more expensive and time-consuming.
Remediation Takes the Most Time
Once gaps are identified, though, the hard work begins. This is where the timeline gets stretched out the most because now, a company is in the process of making changes to policy, procedure, software, physical locations, etc. For most contractors aiming for a Level 2 certification (which most defense contractors will require), the remediation stage typically lasts three to six months. Sometimes longer.
The issue is that companies believe they can purchase software and upgrade a few policies here and there to meet requirements. Still, it requires interdepartmental communication, intra-company compliance, specialized training for new processes and technical controls implemented that weren't previously in place.
For example, companies may have to institute new data flows for controlled unclassified information (CUI), redefine access controls and privileges, establish an incident response plan from scratch with formalized components that didn't exist prior, and take the time to put everything together in a cohesive manner.
Once again, this creates faster resolution through technical fixes than cultural implementations. Implementing multi-factor authentication can be done in a day; ensuring 100% employee compliance moving forward takes months.
Moreover, and this generally surprises most contractors, many of the CMMC requirements implemented take the form of documentation. CMMC requires written proof of presence of policy or procedure existence (and subsequent implementation). Contractors don't just need to implement these security measures; they must also prove they did so by creating documentation when the average business has other priorities at hand. Thus, everything slows down.
Pre-Assessment
Smart contractors will then decide to get a pre-assessment done before the official assessors arrive at their site to determine approval or denial. This dry run takes one to two weeks and will show auditors, and the company, if there are lingering issues that have crept up since the remediation process began that could derail certification approval.
Unfortunately, or fortunately, most companies run into at least one or two minor problems during this pre-assessment evaluation. Their access control measures were insufficient (more investigation was needed); documentation wasn't signed properly; a few employees still weren't in compliance with training.
Contractors should take note: fixing these issues now will add another two to four weeks onto the certification timeline. But fixing these problems now saves them from delaying the actual assessment process and having to start all over again.
Actual Assessment
At this point, assuming everything is in order and compliance is where it needs to be, companies can set their official assessment date. The assessment takes anywhere from two days to two weeks (unless it gets stalled for rework due to issues). A small contractor, say twenty employees or less and a basic IT footprint, might get assessed in two or three days; larger operations with multiple businesses/facilities might take a week or two.
This assessment will involve auditors checking documentation, interviewing employees (selected at random), observing processes in action (or attempted action) and testing technical controls. They're looking for alignment between policy created and presented and what's actually being done at the ground floor, this isn't a paper audit; it's an extensive overview to ensure compliance exists in practice, not just in a document somewhere waiting to be assessed.
Post-Assessment
From here, assuming everything went well, it'll take weeks to officially submit certification and have everything processed. The auditor submits their report, approximately two-to-four weeks from submission for validation, and assuming there are no major findings, low-level issues can be remediated quickly without issue, the company will receive its certification.
If findings exist, minor levels will require quick fixes with limited re-assessment, the major findings mean going back to remediation hell and maybe reassessing nine months down the line.
Timelines Realistically
In totality, a motivated defense contractor starting at a good baseline security level can achieve CMMC Level 2 certification in six-to-nine months. It would take nine-to-twelve months if problems exist/starting security elements are weak or cyber practices were admittedly lacking at the beginning. Those who rush through or cheat find themselves taking longer because they ultimately fail assessments.
Thus, it doesn't take long for an assessment; it takes significant time preparing for it before it's scheduled. Organizations that invest significant time in gap analysis and remediation efforts combined with proper documentation will finish faster than those who speed through just for the sake of getting almost there.
CMMC cannot be crammed for at the last minute; it requires dedication from an organization that has reasonable expectations about how long it actually takes. It won't happen overnight, and it shouldn't, despite an upcoming deadline.
Thanks for signing up to Minutehack alerts.
Brilliant editorials heading your way soon.
Okay, Thanks!