By William Price, Certified CMMC Assessor (CCA) — A³ Vallum CMMC Advisory
The question comes from companies who see the defense market as an opportunity but do not yet have a contract. Should they pursue CMMC certification now to be ready, or wait until a contract requires it? The honest answer is: it depends on what they actually want from the defense market, and whether they understand what CMMC certification gives them.
CMMC is a contract-execution requirement, not a market-entry credential. Pursuing it cold can be a smart investment or a wasted one depending on the company’s actual posture, capital, and roadmap. Here is the full picture I walk companies through when they ask.
What CMMC certification actually gets you
Before deciding whether to pursue CMMC cold, understand what you are buying:
- The right to execute contracts that require CMMC (Basically, all contracts for the Department of War). Once you have it, you can perform on contracts that flow the 7021 clause. This is the core value.
- Credibility with primes evaluating subcontractor portfolios. Primes managing sub portfolios increasingly prefer subs who already have certifications, especially as the staged rollout under 32 CFR § 170.3 expands.
- A documented security posture you can speak to. The artifacts you produce for CMMC (SSP, asset inventory, CRM, evidence library) have value beyond CMMC.
What CMMC certification does not get you:
- DoD contracts. Certification does not produce contracts. It permits performance on contracts that already specify CMMC. Sales cycles are independent of the certification.
- A right to bid on classified work. CMMC governs CUI in nonfederal systems. Classified work has separate clearance requirements.
- Recognition outside the defense market. Commercial customers do not necessarily value CMMC. International customers do not recognize it yet. The credential is DoD-specific.
If a company expects CMMC certification to open doors that are not actually CMMC-gated, the investment may disappoint.
When pursuing CMMC cold makes sense
Three scenarios where we tell companies the cold pursuit is the right call:
1. You have a clear pipeline of CMMC-required work, with target award dates inside 18-24 months. If you are bidding on opportunities that will require Level 2 Certification at award, and the pipeline is real (not aspirational), starting the readiness clock now is appropriate. Level 2 Certification readiness can take anywhere from 3 to 18 months from a clean start; the C3PAO assessment takes 4 to 12 weeks to schedule and complete once ready. Cold-starting after the bid is usually too late.
2. You are entering the defense market deliberately and CMMC is a known cost of entry. Some companies — particularly software companies, manufacturers, or service firms expanding from commercial — make a strategic decision to pursue defense contracts. CMMC is part of the entry cost, alongside marketing, sales, and capability development. In this scenario, CMMC readiness is one line item in a larger market-entry budget.
3. You are positioning for acquisition or partnership. A company building toward acquisition by a defense prime, or a partnership with a defense-adjacent firm, may pursue CMMC to be more attractive at the deal table. The certification is a tangible asset that signals seriousness and reduces integration friction for the acquiring party.
When pursuing CMMC cold is a mistake
The scenarios where we tell companies to consider waiting or just begin implementing the best practices encompassed by CMMC:
1. You have a vague intent to enter defense but no specific opportunity. Pursuing CMMC because “we might want to sell to DoD someday” is rarely worth the investment. Without a contract or a clear pipeline, the certification’s value lives only in the artifacts produced — and those artifacts can be produced through other security frameworks (ISO 27001, SOC 2, NIST CSF) that have broader market value.
2. You have not built basic IT security maturity. A company that has not implemented MFA, has no audit logging, has no documented IR program, and has no asset inventory is not ready for CMMC. The certification is the cap on a mature security program, not the start. Cold-starting CMMC before basic maturity exists can mean an expensive false start.
3. Your business model is fundamentally non-CUI. A company selling COTS (commercial off the shelf) products to DoD without modification often does not need CMMC because the products are not CUI. Some defense sales relationships do not involve CUI at all. Verify the actual contract requirements before assuming CMMC is needed.
4. You cannot afford a $50K-$500K+ readiness investment over 12-18 months. CMMC Level 2 Certification readiness can be expensive. The exact cost depends on starting maturity, environment complexity, and whether you build in-house or use external help, but the all-in cost doesn’t usually land below six figures and often runs higher. A company that cannot fund the investment without crippling other operations should defer.
What “starting cold” actually involves
If you decide to pursue CMMC cold, the path is:
Phase 1: Scoping (1-3 months). Determine what CUI you would handle, where it would live, and what assets would be in scope. Without an actual contract, the scoping is hypothetical, but you can scope to a target customer or contract type.
Phase 2: Architecture (2-6 months). Build the environment. For many cold-starting companies this means selecting GCC High, AWS GovCloud, or some other enclave, setting up the tenant, migrating relevant data and operations, and establishing the security baseline.
Phase 3: Implementation (6-12 months). Implement the 110 NIST SP 800-171 R2 controls. Document the SSP. Build the asset inventory. Establish the responsibility matrix with cloud providers. Stand up SIEM, SOC, IR, vulnerability management, change management, and the rest.
Phase 4: Pre-Assessment Readiness (1-3 months). Run a mock assessment, often with a CCA or RPO. Close the gaps the mock surfaces. Build the evidence library.
Phase 5: C3PAO Assessment (1-3 months). Engage a Cyber AB-accredited C3PAO. Pre-assessment planning, the assessment itself, and the report. If the result is Conditional, you have 180 days to close the POA&M.
Phase 6: Maintenance. The certification is good for three years. Ongoing maintenance, evidence collection, and annual affirmation continue throughout that window.
The realistic cold-start total: 6 to 24 months and significant capital investment.
The “build for CUI handling, defer the certification” middle path
Many companies entering the defense market take a middle path: they build the environment to handle CUI, implement the 110 controls, but defer the C3PAO assessment until they have a contract that requires it.
The advantages:
- Avoid the C3PAO cost until necessary. The assessment itself runs $30K-$100K+ depending on environment complexity.
- The compliance investment is real. The environment can handle CUI under DFARS 252.204-7012 from day one.
- Self-Assessment posture is documented. The contractor can submit a self-assessment SPRS score, which is sometimes sufficient for opportunities that do not require Certification.
- The path to certification is short when a contract requires it. From a 110-control implemented environment, the path to certification is the assessment itself, not 18 months of build.
The trade-off: you cannot perform on contracts that require Level 2 Certification at award. You can bid, you can win, but you cannot start work without the certification. Some contracts allow staged compliance; many do not.
For most companies entering the defense market, the middle path is the right call. Build the environment, document the compliance, defer the certification, and trigger the assessment when the contract economics justify it.
How DIBFI handles this
DIBFI’s phased journey supports cold-start contractors who want to build CUI-handling capability before pursuing certification. The same workflow that takes you to a Self-Assessment SPRS score also gets you to certification readiness — same artifacts, different gate.
What you can do without a CMMC certification today
A company without CMMC can still:
- Bid on most DoD opportunities. Bidding does not require certification. Award does.
- Hold an FCI-handling capability under Level 1, which is self-assessed and does not require a C3PAO.
- Implement 800-171 R2 and submit a self-assessment SPRS score against open contracts that allow it.
- Position for prime/sub relationships where the prime is responsible for the CUI handling and you are providing services that do not directly touch CUI.
- Pursue indirect defense work through commercial customers who supply DoD without flowing CMMC.
The defense market has paths for companies without certification. Certification opens specific doors, not all doors.
What companies most often get wrong about cold-starting
1. Underestimating timeline. “We can be CMMC certified in 6 months” is not always true for a cold start. The realistic floor is 9 months for organized companies starting from a reasonable baseline. 18 months is more typical.
2. Underestimating cost. The compliance investment is not a single budget line. It includes architecture (cloud migration, security tooling), implementation (the 110 controls, which often touch every team), documentation (SSP, asset inventory, evidence library), assessment (C3PAO fees), and maintenance (ongoing operations). The all-in cost over 18 months commonly clears six figures.
3. Skipping the maturity foundation. Cold-start companies sometimes try to implement CMMC controls on top of immature IT operations. The result is documentation that does not match reality. The C3PAO sees through this in the first hour of the assessment.
4. Not aligning sales pipeline with certification timeline. A company that pursues CMMC for 18 months without a parallel sales pipeline ends up with a certification and no contracts. The certification expires in three years; if no work materializes, the recertification cost is wasted.
5. Assuming certification is the end. CMMC is a triennial certification with annual affirmation requirements. The work does not stop at certification. Annual affirmation, evidence maintenance, and re-assessment in three years are all part of the program.
Frequently Asked Questions
Can I get CMMC certified before I have a contract? Yes. Cyber AB-accredited C3PAOs will assess any contractor that engages them, regardless of contract status. The certification is valid for three years from issuance.
Does my self-assessment in SPRS expire? Yes. Self-assessments under DFARS 252.204-7012 should be refreshed annually or when significant changes occur. The SPRS score is a point-in-time measurement.
Can I bid on Level 2 Certification opportunities without certification? Most contracts allow bidding without certification but require certification before award or before performance starts. Read the solicitation. Some allow a path to certification post-award; many do not.
Is there a smaller version of CMMC I can pursue first? Level 1 is self-assessed and covers FCI handling. It is a smaller scope (17 controls vs 110) and does not require a C3PAO. Many cold-starting contractors get Level 1 in place first to handle FCI work, then pursue Level 2 when CUI work materializes.
What does a C3PAO assessment cost? Costs vary widely with environment complexity, scope, and the C3PAO firm. Typical Level 2 Certification assessments run from the low five figures for very small, well-bounded environments to several hundred thousand dollars for large, complex ones. Get multiple quotes from accredited C3PAOs.
Can I lose my CMMC certification mid-cycle? The certification is issued for three years subject to annual affirmation under § 170.22. A material false affirmation, a significant unaddressed cyber incident, or a major scope change can trigger reassessment. The certification is not absolute for three years.
Closing thought
Looks like the contractors who handle the cold-start question well are the ones who treated CMMC as a strategic investment with specific market access value, not a check-the-box credential. The pipeline justifies the investment, the maturity foundation supports the implementation, and the timeline aligns with the contract economics. So if you are weighing the cold start: do you have the pipeline, the capital, and the maturity to make the investment pay back inside the certification cycle?
A³ Vallum runs CMMC readiness for contractors entering the defense market, including cold-start companies weighing the investment. If you want a CCA’s read on whether the certification economics work for your pipeline, reach out.
About DIBFI
DIBFI is a guided CMMC readiness platform that takes contractors from scoping through certification on a phased, gated journey — real-time guidance, all 320+ Level 2 objectives tracked, an interactive SSP Builder, and “Ask an Assessor” when you need a CCA’s read on a specific control.
Sources
- 32 CFR Part 170 — CMMC Program rule, particularly § 170.3 (phased rollout), § 170.17 (Level 2 Certification), § 170.22 (annual affirmation)
- DFARS clause 252.204-7012 — Safeguarding Covered Defense Information
- DFARS clause 252.204-7021 — Cybersecurity Maturity Model Certification Requirements
- NIST SP 800-171 Revision 2 — security requirements
- NIST SP 800-171A — assessment objectives
- CMMC Assessment Process (CAP) v2.0, December 2024, The Cyber AB
- DoD CIO “CMMC Phased Implementation” briefing
- SPRS — Supplier Performance Risk System scoring methodology
