This paper builds upon prior Atlantic Digital (ADI) research examining the financial and operational realities of achieving Cybersecurity Maturity Model Certification (CMMC) Level 2 compliance across the Defense Industrial Base (DIB). ADI’s 2024 “Feasibility of SMBs in the DIB” analysis (ADI, 2024a), explored the economic viability and strategic barriers for small and medium-sized businesses, while another paper (ADI, 2024b) established initial cost models and baseline implementation estimates.

This 2025 update advances that work by integrating newer Department of Defense (DoD) data with independently verified industry benchmarks, including insights from cybersecurity strategist Linda Rust (Rust, 2025) and practitioner commentary. Together, these sources produce an evidence-based view of CMMC Level 2 compliance costs, grounded in official estimates, validated analyses, and practitioner experience.

While cost modeling remains an important objective, the evolving conversation within the DIB has shifted focus from compliance as a technical obligation, to CMMC as a driver of organizational transformation. In line with ADI’s own long-standing posture (ADI, 2024c, ADI, 2024a), defense contractors and industry leaders recognize that CMMC readiness is not a one-time event but an ongoing business discipline that demands executive ownership, sustainable governance, and integrated risk management. In this context, cybersecurity compliance is inseparable from broader strategic and financial planning, shaping how defense suppliers structure their operations, allocate resources, and demonstrate long-term resilience.

Baseline Findings from ADI’s 2024 Analyses

The initial ADI analyses offered an early view of the practical cost burden facing small and medium-sized defense contractors pursuing CMMC Level 2 compliance. Both ADI reports argued that government estimates understated the financial burden for small businesses, focusing on structural and scale disadvantages (ADI, 2024a), and ADI, 2024b further highlighting that recurring internal labor and process maintenance are material components of lifecycle cost. Drawing on DoD data, ADI noted that the projected cost for the Level 2 assessment/affirmation component is approximately $104,670 for a small entity. This figure represents the baseline certification cost, excluding the recurring operational and labor expenses that ADI and others identify as the largest lifecycle contributors (ADI, 2024a; ADI, 2024b). Both papers positioned this baseline as an entry point, not a complete three-year total, indicating that human capital and governance activities are the dominant and most variable cost drivers. Subsequent analyses, including those by Rust (Rust, 2025) and other industry practitioners reinforce this conclusion, confirming that sustained labor, documentation, and process sustainment ultimately define the true economic scope of CMMC Level 2 compliance.

Official DoD Estimates

In January 2025, the Department of Defense published in the draft FAR CUI Rule (2024-30437) a high-level estimate of regulatory familiarization costs for achieving and maintaining CMMC Level 2 compliance. Unlike contractor-derived models that reflect field conditions, the DoD guidelines are designed to provide a benchmark for regulatory and budgeting purposes. In conjunction with the baseline costs described above, these guidelines can be interpreted as comprising three major cost components: one-time implementation—the initial “lift;” recurring operational costs; and third-party assessment costs, as summarized by Rust (Rust, 2025; DoD FAR CUI Rule, 2025; DoD, 2023).

According to the DoD data, the three-year cost for a representative small business is estimated to be approximately $487,970, consisting of $175,700 in initial implementation (labor ~$148,200 + hardware/software ~$27,500); $103,800 in recurring annual costs (labor ~$98,800 + hardware/software ~$5,000), and roughly $104,670 in total assessment costs (DoD FAR CUI Rule, 2025; DoD, 2023). These figures are summarized and discussed by industry analysts, including Rust (Rust, 2025), as the most comprehensive official baseline available.

Taken together, the DoD’s three-year projection implies an average annualized compliance burden of roughly $160,000 per year for a small business, yet industry reports consistently show that real-world costs often exceed this benchmark. Actual expenditures vary widely based on system scope, data complexity, and the maturity of internal controls. In practice, small and mid-sized contractors frequently report higher recurring labor and sustainment costs than the DoD model anticipates, a gap that becomes particularly evident when compared with practitioner-validated data.

In addition, it is important to note that the DoD assumes that defense contractors are already operating in conformance with DFARS and NIST requirements, and therefore treats CMMC certification as a marginal rather than initial compliance effort. In practice, however, many small businesses are still closing foundational gaps, making actual expenditures substantially higher than government projections.

Industry Dialogue and Validation

Practitioner dialogue led by industry expert Linda Rust offers an essential bottom-up validation of how CMMC compliance costs materialize in practice. Her 2025 LinkedIn series presents verified cost benchmarks across company sizes, confirming that CMMC Level 2 compliance can carry a six- to seven-figure price tag when broader programmatic labor, tooling, and sustainment are included (Rust, 2025).

Rust’s posts and the ensuing professional discussion revealed broad consensus that official DoD estimates understate the true scope of effort. While direct C3PAO assessments may range between $50,000 and $75,000 for well-prepared organizations, practitioners emphasized that the majority of expenditures occur earlier, through readiness activities, documentation, and recurring labor required to maintain compliance. These inputs can collectively situate one-time implementation costs between $120K to $250K, with recurring annual expenses of $50K to $100K, yielding multi-year program totals that can exceed $1 million when labor costs are considered (Rust, 2025).

The dialogue also broadened beyond cost precision to organizational behavior and strategic accountability. Industry participants emphasized that CMMC represents a long-term business transformation rather than a one-time audit event, requiring executive ownership, financial planning, and cultural alignment. They noted that poor scoping and inadequate data discovery can inflate costs by 20–30 percent, indicating that efficiency in compliance arises from disciplined governance, clear data boundaries, and proactive leadership engagement. Overall, these practitioner perspectives reinforce ADI’s and Rust’s shared conclusion that human labor and ongoing governance, rather than technology purchases or audit fees, are the largest and most variable components of CMMC Level 2 cost. This consensus reframes CMMC as an ongoing organizational investment in operational maturity and strategic resilience.

Practitioner and Community Corroboration

Practitioner reports from the defense contracting community provide an additional layer of validation grounded in lived experience. While not formally verified, these first-hand accounts help contextualize official and expert data by illustrating how cost variability plays out in practice.

A notable example appears in the Reddit thread titled “Costs for Certified Audit & Mock Audit,” where defense contractors share recent cost experiences. Across dozens of posts, contributors report mock audits ranging from $10K–$30K for smaller, well-prepared firms, with $30K–$50K as a common range for more extensive readiness support. Certified third-party assessments, in turn, often run $30K–$100K+ depending on organizational size, scope, and environmental complexity. Several participants noted that total readiness costs (consulting, remediation, and assessment fees) can approach or exceed $100K for small SaaS and complex IT environments. (r/CMMC, 2025).

These practitioner-level findings reinforce the pattern identified in both ADI and Rust’s analyses where audit fees alone rarely reflect the full economic footprint of compliance. The conclusion across government, professional, and community sources is that effective compliance depends as much on workforce capability and governance discipline as on tooling and assessment preparation.

Integrated Findings and Implications

The data reviewed here present a consistent picture of where CMMC Level 2 compliance costs truly reside. These findings synthesize data from official DoD estimates, ADI’s prior SMB feasibility models, Rust’s professional analysis, and practitioner reports from the CMMC community.

Across all sources, labor (both internal staff time and contracted expertise) emerges as the dominant cost driver, with underestimation of this component explaining much of the gap between official projections and real-world expenditures (ADI, 2024a, ADI, 2024b, Rust, 2025). Recurring subscription and tooling costs form a secondary but still significant component of total cost.

Beyond cost structure, governance maturity, scope definition, and early data mapping emerge as pivotal factors shaping financial outcomes. Industry experts repeatedly note that incomplete scoping or poorly mapped CUI can inflate total cost by as much as 30 percent during the discovery and readiness phases. In practice, this reinforces that cost efficiency is less a function of audit pricing and more a function of organizational readiness and disciplined preparation.

The professional dialogue also highlights that CMMC certification is the beginning, not the end, of a continuous resilience program. Effective programs integrate regular authorization reviews, workforce accountability, and visible executive sponsorship. For small and mid-sized contractors, early strategic planning, structured implementation, and continuous training are the most reliable levers for controlling lifecycle costs. Firms that operationalize CMMC as a business discipline rather than a periodic compliance exercise consistently achieve lower total costs while strengthening long-term security posture.

Atlantic Digital’s approach mirrors these findings. Rather than delivering one-size frameworks or isolated solutions, ADI helps contractors operationalize compliance as a business function. The methodology begins with establishing a readiness baseline and tailored scope definition, followed by cost modeling, control implementation guidance, documentation, training, and pre-assessment validation. The ultimate goal is sustainable compliance that executives can fund, manage, and defend, transforming CMMC from a regulatory obligation into a catalyst for stronger, more resilient operations.

As Linda Rust observed, the Defense Industrial Base will align to these requirements “one business leader at a time” (Rust, 2025). Partnering with advisors who translate the technical rigor of CMMC into practical business language, while understanding both regulatory detail and organizational culture, makes alignment far more achievable. Structured readiness planning and phased implementation allow organizations to mitigate financial and operational strain, even when six- to seven-figure expenditures are involved.

Looking ahead to full CMMC rollout between 2025 and 2028, integrated planning, strategic alignment, and disciplined execution will be essential for maintaining competitiveness, resilience, and long-term contract eligibility across the Defense Industrial Base.

Conclusion

Organizations that approach CMMC integrating cybersecurity into core operations and planning for continuous resilience, will better manage costs, protect critical information, and maintain long-term contract eligibility. Atlantic Digital supports contractors in achieving this configuration through readiness assessments, tailored scope definition, cost modeling, control implementation guidance, pre-assessment validation, and maintenance. By leveraging these services, companies can transform CMMC from a compliance obligation into an opportunity for sustained operational and security excellence.