CMMC Level 3: You Probably Don't Need It

Word count: ~950 Specificity markers: (1) NIST SP 800-172 reference; (2) Time estimate — Level 3 assessment timelines; (4) Common mistake — over-preparing for Level 3 based on assumption; (5) Decision point — how to determine if your contract requires Level 3

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CMMC (Cybersecurity Maturity Model Certification) has three levels. Most defense contractors either need Level 1 or Level 2. Level 3 applies to a much smaller group — and if nobody has explicitly told you that you need it, you almost certainly don't.

This matters because Level 3 is significantly more demanding than Level 2, both in terms of required controls and assessment rigor. Preparing for Level 3 when Level 2 is sufficient wastes resources you need elsewhere. And preparing for Level 2 when you actually need Level 3 is a problem you'll discover at the worst possible time.

Here's how to think about it.

What Each Level Requires

CMMC Level 1 covers the 15 basic safeguarding requirements from FAR (Federal Acquisition Regulation) clause 52.204-21. These protect Federal Contract Information (FCI) — information generated for or provided by the government under a contract that isn't meant for public release. Level 1 is self-assessed annually. No third-party assessor required.

CMMC Level 2 covers the 110 security requirements from NIST (National Institute of Standards and Technology) SP 800-171 Rev 2. These protect CUI (Controlled Unclassified Information) — sensitive government information that requires protection but isn't classified. Most defense contractors who handle technical specifications, engineering drawings, or program information fall here. Level 2 requires a triennial assessment by a C3PAO (Third-Party Assessment Organization), with annual affirmations in between.

CMMC Level 3 adds 24 additional practices on top of Level 2's 110, drawn from NIST SP 800-172. It's designed for organizations protecting CUI associated with DoD's highest-priority programs — think advanced weapons systems, critical defense technologies, and programs under the oversight of the Under Secretary of Defense for Research and Engineering (OUSD(R&E)). Level 3 assessments are conducted by the Defense Contract Management Agency (DCMA), not a C3PAO.

That last point is significant. At Level 3, the government itself assesses you — not a private assessor organization. The process is more rigorous, less predictable, and carries more direct consequences.

How to Tell if You Actually Need Level 3

Your contract tells you. Specifically:

• If your solicitation or contract includes a CMMC requirement, it will specify the level.
• Level 3 requirements will typically reference "advanced" CUI or specific OUSD(R&E)-controlled program information.
• If your contract specifies Level 2, that's your floor — and your ceiling for compliance purposes.

The most common reason contractors incorrectly assume they need Level 3: they're in a supply chain that includes high-sensitivity programs, and they assume the sensitivity of the prime's work flows down to them at the same level. It usually doesn't. Flow-down requirements are specified in your contract. If your contract specifies Level 2 (or doesn't specify a CMMC level at all beyond DFARS 252.204-7012 requirements), Level 3 is not your obligation.

If you're genuinely uncertain — if you're on a program you believe may be Level 3 territory and your contract language is ambiguous — talk to your contracting officer. Don't assume your way into a $500,000 remediation project based on a guess.

What Level 3 Actually Adds

The 24 additional Level 3 practices come from NIST SP 800-172, which is specifically designed to defend against Advanced Persistent Threats (APTs) — nation-state adversaries with sophisticated, patient attack capabilities. The controls are more demanding in several ways:

• More stringent access controls — including additional restrictions on privileged account use and more granular session monitoring
• Enhanced threat hunting — proactive search for indicators of compromise rather than just reactive detection
• More frequent assessment activities — penetration testing is explicitly required at Level 3 under control CA.L3-3.12.1e
• Increased architecture requirements — stricter network segmentation and more prescriptive boundary protection

At Level 3, you're not just securing CUI against opportunistic attackers. You're defending against nation-states that specifically target defense programs. The controls reflect that reality.

The Assessment Process Difference

Level 2 C3PAO assessments typically take four to eight weeks from kickoff to final report, depending on scope. Organizations with 50–200 users in scope should budget $50,000–$150,000 for the assessment itself (not counting remediation work).

Level 3 DCMA assessments operate on a different timeline and process. Because they're government-led, scheduling is less predictable. The rigor is higher — DCMA assessors are looking for evidence of sustained, institutional security practice, not just a compliant snapshot. Organizations pursuing Level 3 should expect 12–18 months of preparation after reaching Level 2 compliance, plus an assessment process that may extend well beyond the Level 2 timeline.

The Common Mistake

The most common Level 3 mistake isn't insufficient preparation — it's unnecessary preparation. Every year, defense contractors invest in Level 3 controls, Level 3 training, and Level 3 consulting when their actual contracts only require Level 2. The investment isn't wasted from a security perspective, but it's money that could have gone toward solidifying Level 2 controls that actually affect assessment outcomes.

The second most common mistake is the opposite: assuming that achieving Level 2 automatically positions you for Level 3 on short notice if a contract requires it. Level 2 is necessary but not sufficient for Level 3. The additional 24 practices aren't trivial, and a DCMA assessment isn't something you spin up in 90 days.

The Decision Point

Do you need Level 3? Answer these questions:

1. Does your current contract explicitly require CMMC Level 3? If yes — you need it. Start the conversation with a consultant experienced in NIST SP 800-172 requirements now.

1. Are you pursuing contracts that you believe may require Level 3? Read the solicitation. Look for language about OUSD(R&E) oversight or advanced CUI. If it's not there, Level 2 is almost certainly sufficient.

1. Are you just worried that Level 2 might not be enough? Worry isn't a planning basis. Get your contracts reviewed by someone who can read the FAR and DFARS clause language and tell you what's actually required.

If the answer to all three is no, focus on Level 2. Get there first, get there well, and you'll be in a far better position than a contractor who chased Level 3 and built neither level properly.

For a deeper look at what Level 2 preparation actually involves, the CMMC Level 2 overview walks through every domain and what assessors expect. Or ask the assistant below — it can help you read your contract requirements.