Preparing for CMMC certification can feel overwhelming, especially for small businesses without dedicated IT security staff. This comprehensive checklist breaks the process into manageable steps, organized by phase, so you can track your progress and ensure nothing falls through the cracks.
Phase 1: Foundation and Planning
Business Assessment
[ ] Determine which CMMC level you need (Level 1 or Level 2)[ ] Identify all federal contracts and their security requirements[ ] Review DFARS clauses in your contracts (especially 252.204-7012)[ ] Determine if you handle FCI, CUI, or both[ ] Establish a CMMC implementation budget[ ] Assign a CMMC project lead or team
Scope Definition
[ ] Identify all systems that process, store, or transmit FCI/CUI[ ] Map data flows for federal contract information[ ] Define your CMMC assessment boundary[ ] Document network architecture and system interconnections[ ] Identify all cloud services used for federal work[ ] Determine which employees need access to FCI/CUI
Gap Analysis
[ ] Assess current compliance against required CMMC practices[ ] Document existing security controls[ ] Identify gaps and deficiencies[ ] Prioritize remediation based on risk and effort[ ] Develop a remediation timeline and budget[ ] Create a Plan of Action and Milestones (POA&M)
Phase 2: Technical Implementation
Access Control
[ ] Implement role-based access control[ ] Establish account management procedures[ ] Enforce least privilege principles[ ] Control remote access[ ] Implement session lock and termination[ ] Control access to mobile devices[ ] Encrypt CUI on mobile devices (Level 2)[ ] Control connections to external systems
Identification and Authentication
[ ] Require unique user accounts (no shared accounts)[ ] Implement strong password policies[ ] Enable multi-factor authentication[ ] Manage authenticator credentials[ ] Disable inactive accounts[ ] Implement replay-resistant authentication (Level 2)
Audit and Accountability (Level 2)
[ ] Enable system audit logging[ ] Define auditable events[ ] Protect audit logs from tampering[ ] Review audit logs regularly[ ] Implement automated audit log analysis[ ] Synchronize system clocks[ ] Retain audit logs per policy
Configuration Management (Level 2)
[ ] Establish system baselines[ ] Implement change control procedures[ ] Analyze security impact of changes[ ] Restrict unauthorized software[ ] Implement application whitelisting[ ] Control and monitor user-installed software
Network Security
[ ] Implement firewall at network boundary[ ] Segment networks (separate CUI from general traffic)[ ] Monitor inbound and outbound traffic[ ] Implement intrusion detection/prevention[ ] Encrypt CUI in transit[ ] Terminate network connections after inactivity[ ] Implement DNS filtering
Endpoint Security
[ ] Deploy antivirus/anti-malware on all endpoints[ ] Enable automatic updates for security software[ ] Implement endpoint detection and response (EDR)[ ] Enable full-disk encryption[ ] Disable unnecessary services and ports[ ] Implement USB device control
Email Security
[ ] Implement email filtering and anti-phishing[ ] Enable DMARC, DKIM, and SPF[ ] Train users on phishing recognition[ ] Implement email encryption for CUI
Data Protection
[ ] Encrypt CUI at rest[ ] Encrypt CUI in transit[ ] Implement data loss prevention (DLP)[ ] Control removable media[ ] Sanitize media before disposal[ ] Implement secure file sharing
Backup and Recovery
[ ] Implement regular backup procedures[ ] Store backups securely (encrypted, offsite)[ ] Test backup restoration regularly[ ] Document recovery procedures[ ] Establish recovery time objectives
Phase 3: Policies and Documentation
Required Documents
[ ] System Security Plan (SSP)[ ] Network diagram (current and accurate)[ ] Data flow diagram showing CUI/FCI flows[ ] Hardware and software inventory[ ] Plan of Action and Milestones (POA&M)[ ] Risk assessment report
Required Policies
[ ] Acceptable use policy[ ] Access control policy[ ] Audit and accountability policy[ ] Configuration management policy[ ] Identification and authentication policy[ ] Incident response policy and plan[ ] Maintenance policy[ ] Media protection policy[ ] Personnel security policy[ ] Physical security policy[ ] Risk assessment policy[ ] Security assessment policy[ ] System and communications protection policy[ ] System and information integrity policy
Required Procedures
[ ] Account management procedures[ ] Change management procedures[ ] Incident response procedures[ ] Backup and recovery procedures[ ] Vulnerability management procedures[ ] Patch management procedures[ ] Media sanitization procedures[ ] Visitor management procedures
Phase 4: Training and Awareness
Security Awareness Training
[ ] Develop training content covering all CMMC domains[ ] Train all employees with system access[ ] Conduct phishing simulation exercises[ ] Document all training completion[ ] Schedule recurring training (at least annually)[ ] Provide role-specific training for IT staff
Incident Response Training
[ ] Train incident response team[ ] Conduct tabletop exercises[ ] Test incident reporting procedures[ ] Practice containment and recovery procedures[ ] Document lessons learned
Phase 5: Assessment Preparation
Internal Assessment
[ ] Conduct internal assessment against all required practices[ ] Document evidence for each practice[ ] Address any findings from internal assessment[ ] Update SSP and POA&M[ ] Verify all documentation is current
SPRS Score Submission (Level 1 and Level 2 Self-Assessment)
[ ] Calculate your SPRS score[ ] Submit score to SPRS[ ] Document date of assessment[ ] Plan for annual reassessment
C3PAO Assessment (Level 2 Third-Party)
[ ] Select a certified C3PAO[ ] Schedule assessment[ ] Prepare evidence packages for each practice[ ] Conduct pre-assessment readiness review[ ] Address any pre-assessment findings[ ] Complete formal assessment[ ] Remediate any assessment findings[ ] Receive certification
Ongoing Maintenance
Monthly Tasks
[ ] Review and update access permissions[ ] Apply security patches and updates[ ] Review audit logs for anomalies[ ] Conduct vulnerability scans[ ] Review and update incident response contacts
Quarterly Tasks
[ ] Review and update system inventory[ ] Conduct security awareness refresher[ ] Test backup restoration[ ] Review and update POA&M[ ] Assess new threats and vulnerabilities
Annual Tasks
[ ] Conduct full self-assessment[ ] Update SSP and all policies[ ] Renew SPRS score submission[ ] Conduct comprehensive risk assessment[ ] Review and update training program[ ] Plan for next year's security improvements
Conclusion
CMMC readiness is a systematic process, not a one-time event. Use this checklist to track your progress, ensure completeness, and maintain your certification over time. Remember: the goal isn't just to pass an assessment—it's to build a security culture that protects your business and your customers.
Ready to Take the Next Step?
Whether you're a small manufacturer seeking defense contracts, a government buyer looking for qualified suppliers, or a business owner pursuing CMMC certification, KDM & Associates and the V+KDM Consortium are here to help.
Join the KDM Consortium Platform today:
Schedule a free introductory session to learn how we can accelerate your path to government contracting success.
Whether you're a small manufacturer seeking defense contracts, a government buyer looking for qualified suppliers, or a business owner pursuing CMMC certification, KDM & Associates and the V+KDM Consortium are here to help.
Join the KDM Consortium Platform today:
[Register as a Supplier (SME)](/register?type=sme) — Get matched with government contract opportunities, access capacity-building resources, and connect with prime contractors.[Register as a Government Buyer](/register?type=buyer) — Discover qualified, defense-ready small businesses and streamline your procurement process.
*Schedule a free introductory session to learn how we can accelerate your path to government contracting success.*
