Article

Five Reasons Contractors Are Not Certified (Even If They Are Ready)

July 21, 2025

1. No Contract Trigger — Yet

Even mature organizations are deferring formal certification until a DFARS clause demands it. This “wait until it’s required” mindset is deeply entrenched, even when internal teams are pushing to move forward.

2. C3PAO Scheduling Isn’t Instant

There are over 70 authorized C3PAOs listed on the CyberAB Marketplace, but not all have completed formal CMMC Level 2 assessments. Even fewer have experience in high-complexity environments like multi-site operations or cloud-native architectures. Coalfire Federal has dozens of completed and scheduled assessments for companies of all sizes and complexities. If you're ready but haven't booked, you're competing for limited qualified capacity even with a team as large as ours. The longer you wait, the more crowded the field becomes.

3. Leadership Hesitation

In many organizations, readiness teams have done their job, but the business side is still saying, “Let’s wait.” Whether it’s budget, perceived risk, or confusion about program status, executive hesitation is a real blocker. We encourage internal IT and compliance  teams to share recent data regarding breaches within the DIB along with the cost of recovery as a realistic and meaningful way to put the cost of compliance in perspective. We have heard many people say compliance does not equal security and it is true that compliance isn’t a replacement for an effective cybersecurity program but we are yet to support a company with CMMC compliance preparations who were not more secure at the end of the engagement.

4. Fear of Going First

Contractors worry about being early. Not just in terms of timeline, but visibility. They ask:

  • What if we fail?
  • What if the bar moves again?
  • What if we interpret a requirement differently than the assessor?

Even with strong programs, these concerns can stall progress. In reality, the first ones to get assessed have felt a great sense of relief and accomplishment and are recognized as leaders.

5. Assessment Isn’t Just a Test — It’s a Lift

Passing a mock assessment and passing a formal CMMC assessment aren’t the same. The formal process involves weeks of evidence prep, coordination, assessor Q&A, and executive participation. If you’re not already engaged with a C3PAO, the next step can feel heavier than expected. A quick call is free and can provide a sense of relief once you understand the roadmap.

What You Can Do While You Wait

We’ve seen organizations unintentionally stall after a strong sprint toward readiness. But staying sharp requires effort, and readiness has a shelf life.

Here’s what Coalfire Federal recommends to avoid drift:

  • Recalibrate with a fresh lens: If your original prep was 6+ months ago, a short-form readiness recheck can highlight subtle gaps or control decay.
  • Pressure-test your “evidence muscle”: Many organizations struggle not with doing the work, but with showing it. Practice assembling artifacts in a timeline-aligned format.
  • Run internal drills using CMMC-style assessor prompts: Keep staff alert and aligned with how real assessors think. (Examples below.)
  • Lock in a C3PAO assessment date: Don’t assume availability will align with your internal schedule. The longer you wait, the harder it may be to find a qualified assessor who can move quickly.

Sample CMMC-Style Assessor Prompts

Use these internally to validate that your team isn’t just ready, but that they are assessment-ready.

Access Control (AC.L2-3.1.2)

“Show us how access is provisioned for a new user and how you validate that access aligns with their job role.”

Audit and Accountability (AU.L2-3.3.1)

“Where are your system logs stored, and how often are they reviewed? Can you show recent evidence of those reviews?”

Configuration Management (CM.L2-3.4.1)

“Show us your baseline configuration documentation. When was it last updated and how do you verify compliance across assets?”

Identification and Authentication (IA.L2-3.5.3)

“Demonstrate how MFA is enforced for remote access to your CUI environment and how that enforcement is monitored.”

Incident Response (IR.L2-3.6.1)

“Describe the last real incident you handled. Where is the documentation, and how did lessons learned affect your plan?”

System and Communications Protection (SC.L2-3.13.8)

“Do you prevent remote activation of collaborative devices like webcams? Show us how this is enforced on company-issued laptops.”

These questions aren’t theoretical. They’re representative of the scrutiny your team will face during a formal assessment. Practicing now ensures your documentation, processes, and people hold up under pressure.

Coalfire Federal’s Perspective: You’re Not Behind — But You Could Fall Behind Quickly

We’ve assessed cloud hyperscalers, prime contractors, and niche manufacturers. The consistent theme? The gap between ready and certified is where things quietly unravel, especially when teams assume they’re done.

If you’re ready but uncertified, now’s the time to act. We can help you maintain assessment readiness, lock in a certification window, or pressure-test your environment with fresh eyes.

Ready for Certification? Or Need a Final Readiness Check?

Coalfire Federal is one of the most experienced C3PAOs in the ecosystem and the first to conduct multiple certified CMMC Level 2 assessments. Whether you’re ready to schedule or need a quick recheck to boost confidence, we’re here to help you cross the finish line.