Security frameworks often sound like a maze of acronyms and paperwork, but CMMC assessments are a real-world test of how defense contractors protect sensitive data. It’s not about writing the longest policy—it’s about proving that what’s written matches what’s happening. The biggest surprises during a CMMC assessment often come from the documentation that seemed “good enough.”
Policy Statements Lacking CMMC-Specific Alignment
Policies are supposed to set the tone for cybersecurity practices, but during a CMMC assessment, generic statements stand out for the wrong reasons. Too many contractors use boilerplate templates without tailoring them to meet CMMC compliance requirements. A vague access control policy that doesn’t speak directly to CMMC level 2 requirements won’t satisfy a c3pao reviewing critical documentation. It’s not just about having a policy—it’s about that policy clearly aligning with the intent of each control.
CMMC level 1 requirements might seem simple, but even those must be grounded in specifics. A statement like “We secure user access” doesn’t explain how, who is responsible, or what tools are used. A well-written policy speaks directly to the CMMC framework and sets the foundation for the procedures and evidence that follow. Without that alignment, even the best operational practices may fail to get credit.
Overlooked Procedures for Incident Response Documentation
Every organization thinks they’ll be ready for an incident—until it actually happens. A CMMC assessment often reveals that while a policy mentions incident response, the procedures aren’t fully documented or followed. CMMC compliance requirements demand more than intentions—they require proof of response steps, communication plans, and evidence that the process has been rehearsed or tested.
It’s one thing to say there’s an incident response team. It’s another to show how that team tracks incidents, documents actions taken, and conducts post-event reviews. CMMC level 2 requirements put a heavy emphasis on preparation and follow-through. A C3Pao expects to see defined steps, responsibilities, and clear logs. Without them, even a real response could be counted as a miss during an assessment.
Ineffective Artifact Mapping to Control Objectives
Artifacts are the breadcrumbs that lead assessors to the truth. But in many cases, those breadcrumbs are scattered, mislabeled, or missing entirely. A CMMC assessment doesn’t reward effort—it rewards clarity and connection. Each piece of documentation must clearly support a specific control objective, and without a proper mapping, assessors are left guessing.
Organizations often submit evidence, hoping it “speaks for itself.” But CMMC compliance requirements are not about implication—they’re about demonstration. If a vulnerability scan supports a control, that connection must be clearly labeled, explained, and tied to the requirement. Clear mapping turns a cluttered evidence folder into a trustworthy record of compliance.
Vague Role Assignments Undermining Accountability Records
In many assessments, one consistent problem emerges: no one really knows who does what. Roles are either too broadly defined or simply not tied to specific security responsibilities. For CMMC level 1 requirements, clear role documentation may be enough, but level 2 raises the bar. It expects assignments to match responsibilities outlined in procedures, audits, and training records.
Assessors look for accountability. If an access control measure exists, who approves access changes? Who audits logs? Saying “The IT team handles it” isn’t enough. C3pao reviewers want to see documented role assignments with named individuals or specific roles tied to tasks. Without that structure, even effective actions fall short of CMMC expectations.
Inconsistent Evidence of Continuous Monitoring Activities
Continuous monitoring isn’t just a checkbox—it’s a rhythm that shows the organization is alert and adapting. But during a CMMC assessment, many organizations fail to present consistent logs, reports, or dashboards that reflect ongoing security awareness. Gaps in the timeline or unexplained pauses in monitoring activity raise flags.
CMMC compliance requirements call for documentation that shows not just that systems are checked, but that checks happen regularly and results are reviewed. A single security scan six months ago won’t suffice. Whether it’s log reviews, vulnerability scans, or alert tracking, the evidence must tell a story of constant oversight. Without it, continuous monitoring becomes a hollow promise.
Unsupported Claims in System Security Plans (SSP)
System Security Plans are the heart of the assessment—and one of the most common areas where claims fall apart. Organizations often describe a secure system but fail to provide the artifacts to back it up. A c3pao expects to see that each claim in the SSP is supported with documentation, whether it’s a screenshot, policy, or log.
Too often, an SSP will state that encryption is in place, but there’s no certificate, config file, or audit result attached. For CMMC level 2 requirements, that disconnect is costly. The SSP must not only explain the “what,” but point directly to the “how” and “where.” Anything else invites doubt and, likely, corrective action.
Poorly Documented Security Awareness Training Efforts
Everyone says their team has been trained. But proving that during a CMMC assessment is another matter entirely. Many organizations struggle to document who attended training, what material was covered, and how frequently sessions occurred. This lack of detail weakens an otherwise strong security program.
For CMMC compliance requirements, especially under level 2, assessors expect a structured training program. That includes sign-in sheets, recorded modules, quiz results, or formal acknowledgment forms. Saying employees “know better” won’t hold up if there’s no paper trail. Training should be more than an annual checkbox—it should be a documented and traceable habit.
