Understanding compliance paperwork shouldn’t feel like solving a puzzle, yet many contractors struggle with the documentation required for CMMC compliance requirements. With evolving rules, shifting audit expectations, and varying security controls, it’s no wonder businesses find themselves lost in the process. Here’s why so many contractors are struggling to meet these documentation demands and how they can better prepare.
Because Regulatory Language Is Complex and Open to Interpretation
The wording in compliance regulations is often filled with legal and technical jargon that leaves room for different interpretations. Contractors attempting to meet CMMC requirements frequently find themselves stuck trying to understand vague phrases, unclear guidelines, and shifting definitions. What seems straightforward on paper can become a roadblock when applied to real-world cybersecurity practices. Contractors often rely on third-party experts to interpret the requirements, but even then, different advisors may have different takes on what’s necessary for full compliance.
One of the biggest challenges is that compliance language doesn’t always provide exact instructions on how to implement security measures. Instead, contractors are given broad objectives and must determine the best way to document their efforts. Without clear-cut instructions, businesses often struggle to figure out what auditors expect to see in their security documentation.
Because Required Security Controls Vary Based on Data Sensitivity Levels
Not all data requires the same level of protection, and that’s where things get confusing. CMMC level 1 requirements focus on basic security practices, while CMMC level 2 requirements demand stricter controls for handling sensitive government data. Contractors often misjudge what level of documentation applies to their specific situation, leading to either over-preparation or, worse, gaps in compliance.
The challenge is that contractors may work with different types of government contracts, some requiring minimal security measures while others demand advanced safeguards. If a business incorrectly classifies its data, it could either invest too much in unnecessary controls or, conversely, fail to meet critical CMMC compliance requirements.
Because System Security Plans Require Detailed Technical Justification
Creating a System Security Plan (SSP) isn’t just about listing security controls—it requires in-depth technical explanations that many contractors aren’t prepared to provide. The documentation must outline not only what security measures are in place but also why they were chosen and how they are maintained over time. Without the right expertise, businesses may find themselves writing vague, incomplete, or incorrect justifications that don’t satisfy compliance auditors.
An SSP must be specific to the contractor’s operations, meaning there’s no simple template that works for every business. Companies often underestimate how much detail is required, assuming a general description of their security efforts will be enough. However, auditors want precise technical justifications, evidence of implementation, and clear explanations of how security measures align with CMMC compliance requirements.
Because Audit Expectations Change with Evolving Compliance Standards
CMMC compliance isn’t static. The requirements and audit expectations continue to evolve, creating a moving target for contractors trying to keep up. What was considered acceptable documentation last year might no longer meet the latest standards. This constant shift leaves businesses scrambling to update their records, sometimes without knowing exactly what changes are necessary.
The unpredictability of audits adds another layer of stress. Contractors may prepare their documentation based on past audits, only to find that new standards require additional evidence, revised security controls, or different formatting. Without clear guidance on these evolving requirements, businesses risk falling behind on compliance, even if they were previously in good standing. Staying informed on the latest updates to CMMC level 1 requirements and CMMC level 2 requirements is critical, but many contractors struggle to dedicate the time and resources needed to keep up with the changes.
Because Vendor-supplied Documentation Does Not Always Align with CMMC Controls
Many contractors rely on third-party vendors for security solutions, assuming that the documentation provided by these vendors will satisfy CMMC compliance requirements. However, vendor-supplied reports and security policies don’t always align with the specific controls required for certification. This can leave contractors with gaps in their documentation that they don’t even realize exist until an audit identifies the problem.
While vendors may offer general security reports or certifications, these documents often fail to address how security measures are implemented in the contractor’s specific environment. Auditors expect businesses to provide customized documentation, showing how vendor solutions fit into their overall cybersecurity strategy. Relying solely on vendor documentation without tailoring it to meet CMMC requirements can result in compliance failures that could have been avoided with a more thorough approach.
Because Evidence Collection for Risk Management Practices Is Often Incomplete
Proving compliance isn’t just about having security controls in place—it’s about having documented evidence that these controls are actively maintained and monitored. Many contractors struggle with gathering and organizing the right evidence, leading to incomplete documentation that doesn’t meet audit standards. Risk management practices must be continuously tracked, but without a structured system for collecting data, businesses may find themselves lacking the necessary proof when it matters most.
Auditors expect to see logs, reports, assessments, and other forms of evidence that demonstrate compliance over time. However, many contractors focus on meeting security requirements without considering how they will prove their efforts during an audit. Without a system for systematically recording and organizing compliance-related activities, businesses risk falling short of CMMC compliance requirements. Implementing a strong evidence collection process is essential, yet many contractors overlook this step until they face an audit and realize their documentation is incomplete.
