Whitepaper

Navigating the Organizational, Operational, Cultural, and Financial Challenges on the Road to CMMC Compliance

December 10, 2025

As organizations across the Defense Industrial Base (DIB) prepare for or pursue Cybersecurity Maturity Model Certification (CMMC) compliance, many encounter significant obstacles that go far beyond technical security requirements. CMMC impacts nearly every dimension of a business: its structure, day-to-day operations, internal culture, financial planning, and overall strategic direction. These challenges often appear interconnected, with deficiencies in one area magnifying difficulties in others. For many small and mid-sized businesses, the shift to a compliance-focused model represents not only a cybersecurity transformation but an organizational transformation as well. This white paper outlines the most common challenges companies face in the journey toward CMMC compliance and provides practical guidance to overcome them effectively.

Organizational Challenges

Many organizations struggle with CMMC because compliance efforts often lack clear ownership and alignment across leadership, technical teams, and operational functions. In many cases, executives initially view CMMC as purely an IT responsibility rather than a business-wide requirement, which slows decision-making and delays resource allocation. This lack of early buy-in leads to insufficient funding, inadequate staffing, and unclear accountability for compliance processes. Compounding this issue is the difficulty many organizations face in identifying and properly scoping systems that handle Controlled Unclassified Information (CUI) or Federal Contract Information (FCI). When boundaries are vague or poorly documented, companies risk securing the wrong assets, overspending on unnecessary protections, or failing audits due to insufficient protection of sensitive data flows.

Guidance:

  • Develop a documented “CMMC readiness roadmap” with clear ownership, responsibilities, timelines, and milestones.
  • Secure executive leadership buy-in by framing CMMC as both a cybersecurity requirement and a business enabler.
  • Define and communicate role accountability for policies, controls, documentation, evidence management, and audits.
  • Conduct a thorough data inventory and classification exercise to identify CUI/FCI and map where they reside.
  • Create well-defined system boundaries and document them in a comprehensive System Security Plan (SSP).
  • Limit CUI scope wherever possible to reduce compliance burden and cost.

Operational Challenges

Operational challenges arise when organizations begin implementing the technical and administrative controls required for CMMC. Legacy systems often cannot support modern security requirements such as multi-factor authentication, robust logging, or secure segmentation, forcing companies to upgrade or replace equipment long before planned refresh cycles. Simultaneously, the increased workload associated with compliance, from drafting policies to building documentation and preparing evidence, strains already overextended IT and operations teams. Smaller organizations frequently lack the personnel needed to implement and maintain compliance without disrupting normal operations. Workflow changes, such as stricter access controls or new security procedures, may also frustrate employees who perceive these measures as barriers to productivity. As a result, operational friction becomes one of the largest barriers to sustained compliance.

Guidance:

  • Conduct a technical gap analysis early to compare existing systems with CMMC requirements.
  • Prioritize remediation efforts based on business risk, implementing controls or upgrades in phases.
  • Use compensating controls or targeted system upgrades when full replacement is not feasible.
  • Engage external experts or managed service providers when internal teams lack capacity.
  • Communicate transparently with staff about the purpose and benefits of new security requirements.
  • Build evidence collection and monitoring into daily workflows, using automation wherever possible.
  • Include supply-chain and vendor compliance considerations in planning and documentation.

Cultural Challenges

Cultural resistance is among the most underestimated challenges in the journey toward CMMC compliance. Organizations that previously operated with minimal cybersecurity constraints often struggle to adapt to the procedural discipline required for compliance. Employees may resist new rules, perceive requirements as bureaucratic or intrusive, or fail to understand the consequences of improper data handling. Without a strong culture of security awareness, compliance becomes superficial, policies exist on paper, but daily practices do not reflect them. Leadership behavior also plays a critical role; if executives or managers circumvent controls for convenience, it sends a message that compliance is optional, undermining organization-wide efforts.

Guidance:

  • Launch a cybersecurity training and awareness program for all employees, including leadership.
  • Emphasize the business rationale behind CMMC to build broad internal support.
  • Assign security champions within departments to reinforce adherence and answer questions.
  • Integrate security and compliance responsibilities into performance expectations.
  • Reinforce that CMMC is an ongoing commitment, not a one-time certification event.

Financial Challenges

Financial challenges often present the most significant barrier for small and mid-sized businesses pursuing CMMC. The cost of compliance can be substantial, particularly at higher maturity levels requiring advanced safeguards for CUI systems. Organizations face both one-time expenses, such as assessments, infrastructure upgrades, and policy development. Ongoing costs include monitoring, training, recurring audits, and cybersecurity tool subscriptions. Many companies underestimate the true cost of compliance, focusing only on technology spending while overlooking documentation requirements, staffing needs, or long-term maintenance. For suppliers with narrow profit margins, these expenses can strain budgets or threaten competitiveness in the defense contracting market. Non-compliance, however, carries an even greater financial risk: loss of access to Department of War (DoW) contracts.

Guidance:

  • Conduct detailed cost planning early, including both initial and recurring compliance expenses.
  • Build compliance costs into contract pricing models to ensure long-term financial sustainability.
  • Assess return on investment (ROI) based on contract eligibility, risk reduction, and competitive advantage.
  • Implement compliance incrementally to spread costs over time.
  • Limit the compliance scope to necessary systems to reduce cost and complexity.
  • Consider partnerships with managed service providers to share or reduce compliance burdens.
     

Strategic Recommendations

Organizations that succeed with CMMC typically view it not as an IT initiative but as an enterprise-wide strategic transformation. Effective compliance depends on coordinated planning across technical, operational, cultural, and financial domains. This requires a structured roadmap, clear governance, investment in training, prudent scoping decisions, and long-term financial planning. By approaching CMMC methodically, organizations can minimize disruption, control costs, and enhance their overall cybersecurity posture.

Conclusion

CMMC compliance is a challenging but necessary undertaking for organizations that handle sensitive defense-related information. The path is often difficult because it requires more than technical upgrades. It demands organizational alignment, operational discipline, a cultural shift toward security, and sound financial planning. While the obstacles can be significant, particularly for smaller firms, they are manageable with a structured, strategic approach. Companies that integrate CMMC into their business planning, engage leadership support, and build sustainable compliance processes will be well positioned to capture DoW opportunities, safeguard critical information, and strengthen long-term resilience.

 

For organizations looking to better understand what CMMC readiness entails, our team is available to share additional resources and answer questions. Talk to an expert today.

Travis Goldbach

Vice President of Strategic Business Development (GTM)

Travis Goldbach is a cybersecurity and compliance leader with 20 years of experience driving growth and go-to-market strategy for federally regulated industries. He currently leads Coalfire Federal’s unified GTM strategy and previously guided AWS toward CMMC certification while helping customers advance secure, scalable compliance in the cloud.

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