As the Department of Defense sharpens focus on cybersecurity, CMMC Level 1, though simpler than Level 2, remains a critical requirement for contractors handling Federal Contract Information (FCI). Yet even with only 17 practices to implement, many companies will still make avoidable mistakes that lead to failed self-assessments, inaccurate SPRS scores, or noncompliance.
Here are the top five mistakes’ contractors are likely to make when preparing for CMMC Level 1, and how to avoid them
1. Treating CMMC as an IT project instead of a business requirement
Many contractors still approach CMMC as something they can hand off to their IT team as a project, when in reality CMMC is an organization wide security measure involving all parts that make up the company. CMMC has requirements around training, physical security, policies, asset tracking, and vendor oversight not just firewalls and MFA. This means that decisions will need to be made by the people in the organization who have the authority to make changes within the company, IT teams usually do not have said authority.
How to avoid this mistake:
• Form a cross-functional CMMC team early.
• Treat CMMC like any other procedure or policy opposed to an IT upgrade.
2. Not knowing where FCI actually lives
If you cannot identify where FCI (Federal contract information) is being held than you cannot protect it. Many contractors underestimate where their FCI exists across their environment. CMMC assessments are scope- driven. If you don’t understand where your FCI is flowing your assessment boundaries will likely be wrong. Poor scoping leads to bigger environments, higher costs, and failed controls.
How to avoid this mistake:
• Conduct a FCI identification exercise: systems, emails, shared drives, vendor portals, cloud apps
• Document your FCI “lifecycle “(creation > storage> access > transmission > disposal)
• Define a clean organized assessment boundary
3. Assuming policies equal compliance
Many organizations think because they have created a policy that they are audit-ready, however this is not the case. CMMC assessors don’t just verify that the policies exist they also need evidence to verify that the procedures are matching the policy. A written policy serves no purpose if there’s no proof it’s being followed.
How to avoid this mistake:
• Implement step by step procedures
• Assign responsibilities accordingly
• Document actual evidence
• Confirm alignment throughout roles
4. Underestimating documentation and evidence requirements
CMMC compliance is built on evidence. Verbal confirmation is never enough. Contractors often fail not because policies aren’t being implemented but because they forget to gather proof of that implementation. Although evidence takes time to generate.
How to avoid this mistake:
• Build a designated placement for evidence
• Gather evidence and organize it as soon as you can so you don’t have to scramble to find it before and audit
• Assign a control owner for each requirement to manage and gather evidence
5. Ignoring supply chain and subcontractor compliance
Many contractors only focus on their own compliance and forget that subcontractors and suppliers who handle FCI also have to meet compliance standards. The DoD consistently holds prime contractors accountable for overall compliance; a non-compliant subcontractor or partner can lead to security risks and data exposure. Many contractors realize too late that their supply chain can’t meat required security levels.
How to avoid this mistake:
• Build a supplier cybersecurity review program
• Require subcontractors to sign flow-down clauses, confirm SPRS scores, and maintain CMMC alignment
• Review supplier security annually
Final thoughts
CMMC level 1 compliance is absolutely achievable, but not for organizations that approach it reactively or superficially. The contractors who will succeed are the ones who treat it as a strategic initiative, start early, and focus on accurate scoping, real implementation, and clear documentation.
Avoid these five common mistakes, and you’ll be ahead of the curve — and ahead of your competitors — when CMMC level 1 requirements start hitting contract bids.