CMMC Guide · Levels

CMMC Levels Compared: Which Level Does Your Company Need?

CMMC has three levels. Level 1 covers basic protection of Federal Contract Information (FCI) with 15 requirements. Level 2 protects Controlled Unclassified Information (CUI) with the 110 requirements of NIST SP 800-171. Level 3 adds 24 enhanced requirements for the most sensitive programs. Your contract, not your company, sets the level.

The three CMMC levels side by side

Level 1Level 2Level 3
ProtectsFCICUICUI in the most critical programs
Requirements15, from FAR 52.204-21110, from NIST SP 800-171 Rev 2Level 2 plus 24 from NIST SP 800-172
Assessed byYour companyYour company or a C3PAO, as the contract statesDCMA DIBCAC (government)
How oftenEvery yearEvery three yearsEvery three years
To passAll 15 metAll 110 met, or at least 88 points with a short plan of actionAll met, or at least 80% with a short plan of action
Plan of action (POA&M)Not allowedAllowed for limited items; close within 180 daysAllowed for limited items; close within 180 days
Annual affirmationYesYesYes, for both Level 2 and Level 3
PrerequisiteNoneNoneFinal Level 2 (C3PAO) status
Allowed in new contracts todayYes (Self)Self only; C3PAO pausedPaused

Details for each level: Level 1 · Level 2 · Level 3

Which CMMC level do you need?

Answer three questions, in this order:

  1. What does the contract say?

    Solicitations that include CMMC name the required level and assessment type through DFARS 252.204-7021. If you are a subcontractor, your prime will pass this requirement to you.

  2. Will you handle CUI?

    If you will process, store or transmit CUI, you need at least Level 2. If you will handle only FCI, Level 1 is enough.

  3. Is it a critical program?

    Level 3 applies only when the Department of War specifies it for its most critical programs and technologies. Most contractors will never need it.

Not sure which information you hold? See FCI vs CUI.

Can a company hold more than one CMMC level?

Yes. CMMC status is recorded per information system, so a company can keep CUI in a separate, smaller environment at Level 2 while the rest of its network stays at Level 1. A Level 2 status also satisfies Level 1 for the same scope. Level 3 always sits on top of a Final Level 2 (C3PAO) status for the same systems.

How to draw those boundaries: CMMC scoping.

Questions about CMMC levels

Are there still five CMMC levels?

No. The first version of CMMC had five levels. The current program, often called CMMC 2.0, has three: Level 1, Level 2 and Level 3.

Does Level 2 always require a third-party assessment?

No. The contract states whether Level 2 is a self-assessment or a C3PAO certification assessment. While Phase 2 is suspended, new contracts may require only the self-assessment.

Can we choose a higher level than the contract requires?

Yes. Contracting officers accept the required level or higher, so a higher status never disqualifies you. It does, however, take more effort to achieve and maintain.

Know your level. Plan the work.

CMMCMARK helps defense contractors confirm their CMMC level, prepare for assessment and train the people involved.

Prefer the phone? Call +1 (202) 867-8444.

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