Understanding compliance frameworks can feel like trying to read a map without a key. CMMC Level 2 introduces a stricter set of security measures, but some of its requirements leave businesses scratching their heads. From ambiguous scoping rules to unclear monitoring expectations, these challenges make compliance a daunting task. Here’s a breakdown of the most confusing aspects that need clarification.
Ambiguous Scoping Rules That Leave Businesses Unsure About What Systems to Secure
One of the biggest challenges with CMMC Level 2 requirements is determining which systems need to be secured. The guidelines mention protecting Controlled Unclassified Information (CUI), but they don’t always clarify which assets fall under this category. Companies handling both CUI and non-CUI data often struggle to draw a clear boundary between systems that need full compliance and those that don’t. This uncertainty can lead to either over-securing unnecessary assets or missing critical ones that should be protected.
Without clear scoping rules, businesses risk implementing security controls unevenly. Some may apply CMMC compliance requirements across their entire network, increasing costs and operational complexity. Others may take a limited approach, securing only what they assume is necessary, leaving vulnerabilities in their environment. More detailed guidance on defining the scope of protected systems would help businesses apply security measures more effectively while avoiding unnecessary burdens.
Overlapping Security Controls That Cause Confusion in Implementation and Documentation
Many security controls in CMMC Level 2 mirror those from NIST 800-171, but the overlap isn’t always straightforward. Some requirements seem to cover the same security principles but have different wording or additional expectations. This creates confusion when businesses document their compliance efforts. Are they supposed to provide separate evidence for each requirement, or can one control satisfy multiple requirements at once?
This overlap also complicates implementation. Organizations may already follow security best practices under other frameworks but struggle to align them with CMMC compliance requirements. Instead of simplifying cybersecurity efforts, unclear distinctions between overlapping controls lead to redundant work. A more streamlined approach, with better guidance on mapping controls between frameworks, would prevent unnecessary duplication and make compliance easier to manage.
Cloud Service Provider Compliance Uncertainty That Puts Data at Risk
Many businesses rely on cloud service providers (CSPs) to store and process sensitive information, but CMMC Level 2 requirements don’t always clarify how compliance extends to these third-party services. While CMMC acknowledges the importance of secure cloud environments, it doesn’t specify which security responsibilities fall on the CSP versus the customer. This lack of clarity leaves businesses uncertain about whether their cloud providers meet compliance standards or if they need to implement additional controls on their own.
Organizations using commercial cloud solutions must ensure their providers align with CMMC requirements, but this is easier said than done. Some CSPs may claim compliance without fully meeting the necessary security controls, putting customer data at risk. Businesses need better guidance on evaluating cloud service compliance, ensuring their sensitive information remains protected without assuming their provider has everything covered.
Unclear Expectations for Continuous Monitoring and Real-time Threat Detection
Continuous monitoring is a key component of strong cybersecurity, but CMMC Level 2 requirements don’t define exactly what this should look like. Businesses are expected to detect and respond to threats in real-time, but the framework doesn’t specify the level of monitoring necessary. Should organizations have a dedicated security operations center? Are automated threat detection tools required? How frequently should logs be reviewed? Without clear expectations, companies risk falling short of compliance without realizing it.
The lack of specificity also makes it difficult to budget for compliance. If businesses don’t know whether basic log monitoring is enough or if they need full-scale threat detection, they may either overspend on unnecessary tools or fail to implement required security measures. More explicit guidelines on what constitutes effective continuous monitoring would help companies allocate resources effectively while meeting CMMC requirements.
Supply Chain Security Confusion That Makes Vendor Risk Assessments a Challenge
CMMC Level 2 places a heavy focus on securing the supply chain, but many businesses struggle to assess vendor compliance. The framework requires companies to ensure their suppliers follow the same security practices, but it doesn’t always explain how to verify this. Should businesses conduct audits? Rely on vendor attestations? Request third-party certifications? The lack of standardization makes supply chain security a difficult task.
Many organizations work with dozens or even hundreds of vendors, and manually verifying each one’s security posture is unrealistic. Some businesses may assume their suppliers are compliant without actual proof, introducing risk into their environment. Others may overburden vendors with compliance demands, leading to friction in business relationships. More standardized approaches to vendor risk assessments would help companies enforce security requirements across their supply chain without unnecessary complexity.
Data Classification Guidelines That Leave Companies Guessing About Protection Levels
Protecting Controlled Unclassified Information is central to CMMC Level 2 compliance, but the process of classifying data is not always clear. Businesses must identify which information qualifies as CUI and ensure it is properly secured, but the guidelines for classification can be vague. If companies misclassify data, they may either overprotect harmless information or fail to secure sensitive assets properly.
The confusion stems from the fact that different agencies and contractors may interpret CUI classification differently. Some businesses may not even realize they are handling CUI, leaving them unprepared for compliance requirements. Others may struggle to track where CUI is stored and how it is accessed. More precise classification criteria and standardized methods for identifying and labeling CUI would help companies confidently protect their data while ensuring they meet CMMC Level 2 requirements.
