Navigating the path to CMMC compliance can be a complex task. Between evolving DoD requirements and assessment preparation, there are dozens of opportunities to get it wrong. That’s why a clear, structured CMMC checklist isn’t just helpful. It’s essential.At Sera Brynn, we’ve spent years guiding defense contractors and suppliers through the CMMC readiness process. As a FedRAMP 3PAO and CMMC C3PAO (in process) with deep expertise in NIST-based cybersecurity frameworks and federal regulations, we understand both the letter of the law and the real-world challenges contractors face. Our approach is designed to help organizations not just pass certification but build a resilient cybersecurity program.
If your business touches Controlled Unclassified Information (CUI) or supports DoD contracts, this checklist is your roadmap. We’re here to help you achieve certification.
What are the 7 Stages to CMMC Compliance |
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1. Learn the Basics |
The first step is to understand CMMC, evaluate your contractual obligations today and in the future, and confirm that your organization has a clear business case for certification. |
2. Define Your Scope |
Determine the appropriate CMMC level for your organization based on contracts. Next, define the scope by identifying the people, systems, and processes that must align with CMMC compliance requirements. |
3. Document Your Current State |
Create detailed documentation of all people, systems, and processes in scope. This should cover your System Security Plan (SSP), defined boundaries, supporting diagrams, policies, procedures, implementation plans, and inventories. |
4. Identify Your Gaps |
Evaluate your cybersecurity program against CMMC requirements through a Gap Assessment. Capture all deficiencies and prepare a preliminary Plan of Action and Milestones (POA&M) to guide remediation. |
5. Develop Your Compliance Program |
Create a step-by-step remediation plan to resolve gaps, document progress, and compile a body of evidence. Train and prepare your team for the upcoming external assessment. |
6. Undergo Assessment |
Partner with an authorized C3PAO (assessor) for a mock assessment, resolve your issues, and finalize documentation before advancing to the formal CMMC certification process. |
7. Sustain Your Security Program |
Post-certification, focus on continuous monitoring, consistent evidence collection, and ongoing program enhancements to sustain compliance. |
Your Step-by-Step Guide to Certification Readiness
Use this checklist to track your organization’s progress toward Cybersecurity Maturity Model Certification (CMMC), from initial understanding to full certification and ongoing compliance.
Step 1: Learn the Basics
☐ Learn the CMMC compliance program, its levels, controls, and objectives
☐ Assess current and future contracts to identify your organization’s CMMC obligations
☐ Evaluate the ROI and create a business case to decide if CMMC certification is the right investment for your business
Step 2: Define Scope
☐ Identify the target CMMC level that best fit your organization based on your contracts
☐ Identify all in-scope assets and define boundaries
- All people, facilities, and technologies with access to CUI
- All systems that process, store, or transmit CUI
- All Security protection assets (SPA) and contractor risk-managed assets (CRMA)
- All cloud service providers (CSP) and external service providers (ESP) processing CUI
☐ Pro Tip: Minimize scope wherever possible and consider enclaves and/or segmentation
Step 3: Document Current State
☐ Create thorough documentation for everything in your compliance scope
- System Security Plan (SSP)
- Network, system boundary, and data flow diagrams
- Asset inventories and configuration baselines
- Policies, procedures, and plans
☐ Document CSPs and ESPs (handling CUI)
- Verify FedRAMP Moderate authorization or DoD-accepted equivalency (for CSPs)
- Update contracts and gather customer/shared responsibility matrix (CRM/SRM)
☐ Pro Tip: Create detailed documentation to the control objective level
Step 4: Identify Gaps
☐ Conduct a formal gap assessment
☐ Compare your current posture against CMMC requirements (320 control objectives)
☐ Document missing controls and requirements
☐ Draft an initial Plan of Action and Milestones (POA&M) with timelines and responsible stakeholders
Step 5: Develop Compliance Program
☐ Create a detailed implementation plan based on the POA&M
☐ Remediate deficiencies identified in the gap assessment
- Assign internal responsibilities and set timelines for each control
☐ Build your Body of Evidence (BoE)
- Collect relevant artifacts that demonstrate control effectiveness at the objective level
☐ Prepare your team for the C3PAO assessment
- Train staff on interview readiness and evidence presentation
- Ensure documentation is complete, current, and accessible
☐ Establish an internal compliance oversight team
☐ Track compliance metrics and integrate into executive reviews
☐ Regularly review and update policies, controls, and documentation for accuracy and effectiveness
☐ Monitor DoD updates and changes to the CMMC framework
☐ Pro Tip: Your evidence must prove that controls are established and proven to work reliably over time, not just now, but in the past and moving forward
Step 6: Undergo Assessment
☐ Select a certified CMMC Third-Party Assessment Organization (C3PAO)
☐ Perform a mock assessment
☐ Remediate any findings and update documentation
☐ Undergo the formal C3PAO assessment
- Phase 1: Planning – Define scope, schedule, and review readiness
- Phase 2: Assessment – Collect and evaluate evidence through documentation, interviews, and testing
- Phase 3: Reporting – Document results, share findings, and submit to DoD
- Phase 4: Wrap-Up – Close out the assessment, finalize records, and secure artifacts
*After Phase 1, the C3PAO will determine if you can proceed through the assessment.
Step 7: Sustain Your Security Program
☐ Establish a compliance governance process to oversee long-term maturity
☐ Maintain continuous compliance in line with your CMMC level
- Level 1: Annual self-assessment
- Level 2: Triennial C3PAO assessment and annual self-assessments
- Level 3: Government-led assessment every three years
☐ Conduct regular internal audits to verify ongoing compliance
☐ Regularly update and test policies, plans, and incident response procedures
☐ Drive continuous improvement through lessons learned and evolving best practices
Why This Checklist Matters NowWith the final 48 CFR rule submitted and enforcement poised to begin as early as late 2025, contractors can’t afford to wait. Implementing NIST SP 800-171 controls, closing compliance gaps, and preparing for a C3PAO assessment often takes 9 to 12 months, even for well-resourced organizations. |
Ready to Start Your CMMC Journey?
The path toward CMMC compliance might be difficult, but thankfully, you don’t have to do it alone. Trust Sera Brynn to power your CMMC journey.
At Sera Brynn, we know what it takes to meet the standard. As a FedRAMP 3PAO, GovRAMP (StateRAMP) 3PAO, and CMMC C3PAO (in process) with deep expertise in NIST-based frameworks and DoD contracting, we don’t just help you get certified, we help you build a program that’s secure, sustainable, strategically aligned to your business goals, and ultimately win more contracts.
Schedule a free consultation with a Sera Brynn expert today.
You can also check out the following resources for more info about CMMC compliance:
- CMMC Compliance For Small Businesses: A Comprehensive 2025 Guide
- Cybersecurity Practices That Can Make or Break Your CMMC Compliance