Preparing for a CMMC Level 2 audit is a critical milestone for any organization that handles Controlled Unclassified Information (CUI) in contracts with the U.S. Department of Defense (DoD).
Achieving Level 2 compliance is more than just meeting a regulatory requirement—it demonstrates to the DoD and prime contractors that your cybersecurity program is mature, reliable, and capable of protecting sensitive information.
Unlike CMMC Level 1, which permits organizations to complete a self-assessment, Level 2 mandates a rigorous evaluation conducted by a Certified Third-Party Assessor Organization (C3PAO). This formal audit ensures you have fully implemented the security practices outlined in NIST SP 800-171 and that they are functioning effectively across your environment.
If you’re preparing for this assessment, the best place to start is understanding what auditors look for and how to position your organization for a smooth, successful audit. Here’s how to get ready:
1. Understand the requirements
CMMC Level 2 is built directly on the NIST SP 800-171 framework, which outlines 110 cybersecurity practices across 14 security domains. These domains span every major aspect of protecting Controlled Unclassified Information, including:
- Access control – ensuring only authorized users and systems can access CUI
- Incident response – detecting, reporting, and responding to cybersecurity events
- System and communications protection – safeguarding data in transit and at rest
- Risk assessment – identifying and evaluating potential threats
- Configuration management – maintaining secure, well-documented system configurations
To prepare effectively, start by reviewing the full list of NIST SP 800-171 requirements and mapping each one to your current cybersecurity posture. This helps you identify where controls already exist, where they need improvement, and where new safeguards must be implemented.
It’s also important to look beyond the 110 controls themselves. Organizations must understand the 320 assessment objectives defined in the CMMC Level 2 Assessment Guide. These objectives break each control into detailed, testable components and provide a clear roadmap of what a C3PAO will examine during the audit.
In short, the better you understand the requirements—and how they will be evaluated—the more efficiently you can prepare for a successful assessment.
2. Conduct a gap analysis
Once you understand what CMMC Level 2 demands, the next step is to determine how your current environment measures up. A comprehensive gap analysis helps you pinpoint exactly where your organization falls short of the required controls and what must be addressed before undergoing an assessment.
This process typically includes:
- Reviewing existing policies and procedures to ensure they align with NIST SP 800-171 requirements and are consistently followed across the organization
- Assessing technical controls, such as access management, logging, encryption, and endpoint protection
- Evaluating staff training and awareness, confirming that employees understand their security responsibilities and how to handle CUI
- Documenting areas of non-compliance and creating a clear, prioritized remediation plan
A well-executed gap analysis not only identifies what’s missing but also uncovers inconsistencies, outdated processes, or controls that are implemented but undocumented—issues that can lead to audit failures.
Because this step requires both technical and compliance expertise, many organizations choose to partner with managed service providers (MSPs). These experts can bring an objective perspective, reduce the burden on internal teams, and help ensure no gaps are overlooked.
3. Develop a system security plan (SSP)
Your System Security Plan (SSP) is one of the most important documents in the CMMC Level 2 audit process. It serves as the authoritative record of how your organization implements each of the 110 security practices and provides auditors with a clear understanding of your cybersecurity environment.
An SSP should include:
- Descriptions of systems and environments
- Defined roles and responsibilities
- Implementation details for every control
Because the SSP acts as a roadmap for the assessment, accuracy, clarity, and completeness are critical. Any gaps, inconsistencies, or outdated information may raise concerns during the audit and delay certification.
Ultimately, a well-prepared SSP not only demonstrates compliance but also shows that your organization has a mature, well-structured security program capable of safeguarding CUI.
4. Create a plan of action and milestones (POA&M)
If your gap analysis uncovers deficiencies—and for most organizations, it will—the next step is to create a Plan of Action and Milestones (POA&M). This document outlines how you plan to remediate gaps and move toward full compliance with CMMC Level 2 requirements.
An effective POA&M should:
- Identify specific remediation tasks, clearly describing what needs to be fixed, updated, or implemented
- Assign responsible parties, ensuring accountability for each action item
- Set realistic timelines and milestones, providing a measurable roadmap that tracks progress toward completion
Auditors understand that not every control may be fully implemented at the time of the assessment, but they will expect to see meaningful progress and a well-documented plan that demonstrates your commitment to achieving full compliance.
A clear, actionable POA&M not only supports audit readiness but also strengthens your overall security posture by prioritizing and organizing remediation efforts.
5. Implement technical and administrative controls
With your gaps identified and your remediation plan in motion, the next step is to fully implement the required technical and administrative controls. For CMMC Level 2, these controls must not only exist—they must be functional, consistently applied, and thoroughly documented.
Key controls include:
- Multi-factor authentication (MFA) to strengthen identity and access management
- Encryption for data at rest and in transit to ensure CUI is protected wherever it resides
- Endpoint protection and continuous monitoring to detect malicious activity and maintain system integrity
- Role-based access controls (RBAC) to ensure users only have the permissions necessary for their job duties
- Incident response procedures that outline how your organization identifies, reacts to, and recovers from security incidents
Implementing controls is not a “check-the-box” exercise. Auditors will look for evidence that these safeguards are fully operational, consistently enforced across your environment, and supported by documented policies, procedures, and system configurations.
6. Train your team
Cybersecurity—and CMMC compliance—is a team-wide responsibility. Even the strongest technical controls can fail if employees aren’t aware of their responsibilities or how to identify and report potential threats.
To support a successful audit:
- Provide regular security awareness training for all employees, ensuring they understand how to properly handle CUI, recognize phishing attempts, and follow established security procedures.
- Equip technical and administrative staff with role-specific training, so they fully understand the controls they manage, the documentation they maintain, and their responsibilities in sustaining compliance.
During a CMMC Level 2 assessment, auditors may interview personnel to confirm that policies and procedures are being followed in practice, not just on paper. Well-trained employees demonstrate operational maturity and can significantly improve audit outcomes.
7. Perform a mock audit
Before scheduling your official CMMC Level 2 assessment, it’s wise to conduct a mock audit to simulate the real evaluation process. This rehearsal allows your team to experience the structure, questions, and documentation expectations of a formal audit—without the pressure of the final score.
A well-executed mock audit helps you:
- Identify overlooked issues or areas where controls are implemented but not clearly documented
- Test your Validate your documentation, ensuring your SSP, POA&M, policies, and procedures accurately reflect your cybersecurity program
- Prepare staff for auditor interactions, giving them confidence in explaining their responsibilities and demonstrating compliance
Many organizations choose to bring in external assessors or consultants to ensure an objective, thorough dry run. Increasingly, some C3PAOs are offering combined services—conducting a mock audit and then transitioning directly into the formal assessment.
This approach can be especially beneficial: it saves time, reduces stress, and helps Organizations Seeking Assessment (OSAs) feel more confident heading into what can otherwise be a high-stakes, high-pressure process.
8. Engage a C3PAO
When you’re confident that your controls, documentation, and processes are in good shape, it’s time to schedule your formal CMMC Level 2 assessment with a C3PAO.
However, timing matters. With fewer than 100 authorized C3PAOs and tens of thousands of organizations expected to pursue Level 2 certification, demand will quickly outpace availability. It’s important to book early, ideally securing an audit slot in 2026, before certification requirements become widespread in new DoD contracts.
During the assessment, be prepared to:
- Provide comprehensive documentation, including your SSP, POA&M, policies, procedures, and technical evidence
- Demonstrate control implementation across your systems and processes, showing auditors that each requirement is fully operational
- Answer detailed questions about your cybersecurity practices, ensuring your team can clearly articulate how controls work and how CUI is protected
By engaging early, preparing thoroughly, and ensuring your team is ready, you significantly improve your chances of a smooth, successful certification process.
Final thoughts
Preparing for a CMMC Level 2 audit is no small task—it requires time, coordination, and a deep commitment to cybersecurity. But it’s also an invaluable opportunity to strengthen your security posture, reduce risk, and build trust with partners across the Defense Industrial Base.
By taking a structured, disciplined approach—and leveraging expert guidance when needed—you can confidently meet the requirements, demonstrate your organization’s maturity, and position yourself for long-term success in supporting DoD contracts.
If you need support along the way, our team is here to help you navigate every step with clarity, confidence, and proven expertise. Read more about how Field Effect supports CMMC compliance, or reach out to us today!
