The Real Reason CMMC Costs Are Shocking Companies
Well before the Cybersecurity Maturity Model Certification (CMMC) went into effect in November 2025, a major concern within the defense industrial base was the cost of attaining and maintaining certification.
Now that the phased rollout of CMMC is well underway, some companies report that the accumulation of complex and costly regulatory requirements is forcing them to reconsider—if not exit—the defense marketplace altogether.
In fact, industry analysts project that 15% to 20% of the DIB, representing 33,000 to 44,000 companies, may exit the defense market entirely because compliance costs exceed the value of their work with the Department of Defense.
It’s important to understand that security investments are not a new requirement, they have been in place for years as noted in National Institute of Standards and Technology (NIST) SP 800-171r2, required under DFARS 252.204-7012. CMMC is only validating these pre-existing cybersecurity standards. As a result, if implementation and preparation costs have not already been considered, current cost pressures reflect not a new mandate, but delayed compliance.
Implementation vs. Assessment Cost
Implementation and assessment efforts represent fundamentally different stages of CMMC. Implementation cost is what contractors spend to build and operationalize a compliant environment. This includes implementing technical controls, defining scope, establishing boundaries, developing documentation, and ensuring policies and procedures are actually in practice. Implementation is not a new expectation.Contractors that store, process, and/or transmit controlled unclassified information (CUI) have been required to implement requirements outlined by NIST SP 800-171 since 2017. CMMC does not introduce these requirements; it introduces verification through assessment.\
Assessment cost, on the other hand, is what contractors, or Organizations Seeking Certification (OSCs), spend to validate what has been implemented. It is a point-in-time evaluation conducted by a CMMC certified third-party assessor organization (C3PAO) to confirm that controls are in place and functioning as intended.
One of the most common challenges in the market today is that organizations continue to group these costs together, often because implementation was not completed in advance. That results in OSCs implementing controls while simultaneously pursuing assessment, rather than following the model CMMC was built on (which assumes contractors have already implemented these requirements).
This blurring of costs is also the core driver of cost shock. The DoD’s official estimates for a Level 2 third-party certification range from $104,670 for small entities to $117,768 for larger entities over three years — but those figures cover only assessment, certification, and affirmation activities, and notably exclude gap assessments, mock assessments, remediation, and pre-assessment consulting.
The rule explicitly states that implementation costs are excluded because the implementation costs of DFARS 7012 were adjudicated during that rulemaking. Notably, these two figures are remarkably close despite representing vastly different-sized organizations, reflecting the DoD’s standardized assessment model, which does not account for environmental complexity, scope size, or the depth of remediation required. In practice, the gap between small and large organization costs is far wider than the government estimates suggest.
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