A Complete Guide to the CMMC Level 2 Audit: What Organizations Need to Know

AKRUP
Jan 5
3 min read

Updated: Jan 6

The Cybersecurity Maturity Model Certification (CMMC) has become a defining requirement for companies working with the U.S. Department of Defense (DoD). Among its three maturity levels, CMMC Level 2 is the most widely applicable—targeting contractors that handle Controlled Unclassified Information (CUI). For these organizations, passing a Level 2 audit is not just a compliance checkbox; it’s a gateway to maintaining eligibility for DoD contracts.

This article breaks down what the CMMC Level 2 audit involves, how organizations can prepare, and what to expect throughout the assessment process.

🔐 What Is CMMC Level 2?

CMMC Level 2 represents an advanced cybersecurity posture aligned closely with NIST SP 800‑171, requiring organizations to implement 110 security controls across 14 domains. These controls are designed to protect CUI from unauthorized access, theft, or compromise.

Level 2 is required for:

Prime contractors handling CUI
Subcontractors receiving CUI from primes
Organizations participating in sensitive defense programs

Unlike Level 1, which allows self-assessments, Level 2 requires a third‑party audit conducted by a CMMC Third-Party Assessment Organization (C3PAO) for most contracts.

🧭 What the Level 2 Audit Evaluates

A CMMC Level 2 audit examines whether your organization has fully implemented and can consistently demonstrate the 110 required practices. Key areas include:

1. Access Control

Role-based access
Multi-factor authentication
Least privilege enforcement

2. Incident Response

Documented response plans
Reporting procedures
Post-incident analysis

3. Configuration Management

Baseline configurations
Change control processes

4. Risk Management

Regular risk assessments
Mitigation strategies

5. System & Information Integrity

Vulnerability scanning
Patch management
Malware protection

The audit focuses on evidence, not just policy. Assessors want to see that controls are implemented, monitored, and repeatable.

📝 What Happens During a CMMC Level 2 Audit?

A typical Level 2 audit unfolds in three phases:

1. Planning & Scoping

The C3PAO works with your organization to:

Define the assessment boundary
Identify systems storing or transmitting CUI
Review your System Security Plan (SSP)

A well-scoped environment reduces cost, complexity, and risk.

2. Assessment Activities

Assessors evaluate your compliance through:

Documentation review
Interviews with personnel
Technical testing
Evidence collection (screenshots, logs, configurations)

Each of the 110 practices is rated as:

Met
Not Met
Not Applicable

3. Reporting & Certification

If all practices are met:

The C3PAO submits results to the CMMC Accreditation Body
Certification is issued and valid for three years

If gaps are found:

Organizations may receive a Plan of Action & Milestones (POA&M) for limited remediation
Not all controls are eligible for POA&M treatment

🧩 How to Prepare for a Level 2 Audit

Preparation is the most important part of the process. Successful organizations typically follow these steps:

1. Conduct a NIST SP 800‑171 Self-Assessment

This identifies gaps early and establishes your SPR score in the Supplier Performance Risk System (SPRS).

2. Build a Complete System Security Plan (SSP)

Your SSP must:

Describe your environment
Document each control
Explain how CUI flows through your systems

3. Implement Required Policies & Procedures

Assessors expect formal, documented, and consistently applied processes.

4. Collect Evidence in Advance

Examples include:

Access control lists
MFA logs
Patch reports
Incident response exercises

5. Limit the Assessment Scope

Use strategies like:

Network segmentation
Dedicated enclaves
Cloud service providers with FedRAMP Moderate or High

6. Conduct a Mock Audit

A readiness assessment helps identify weak points before the official audit.

🚧 Common Challenges Organizations Face

Many companies struggle with:

Incomplete documentation
Lack of MFA across all systems
Weak logging and monitoring
Poorly defined incident response processes
Unclear CUI boundaries

Addressing these early prevents costly delays during the audit.

🎯 Why CMMC Level 2 Matters

Beyond compliance, achieving Level 2 certification:

Strengthens your cybersecurity posture
Builds trust with DoD partners
Protects sensitive national defense information
Enhances competitiveness in the defense industrial base

In an era of escalating cyber threats, Level 2 is both a requirement and a strategic advantage.

📌 Final Thoughts

A CMMC Level 2 audit is a rigorous but achievable milestone. With proper preparation—clear documentation, strong technical controls, and a well-defined scope—organizations can navigate the process confidently and secure their place in the DoD supply chain.

#CMMC