Handling Non-Compliance & Corrective Actions in CMMC
Handling Noncompliance and Corrective Actions in CMMC: What the Final 48 CFR Rule Means for Contractors
Key Takeaways
Contractors failing a CMMC assessment but meeting 80 percent of required controls may receive Conditional Certification.
Plans of Action and Milestones (POA&Ms) must be resolved within 180 days or certification is lost.
Certain critical security controls cannot be deferred and must be implemented before achieving Conditional Certification.
Introduction
The Cybersecurity Maturity Model Certification (CMMC) program represents a crucial compliance milestone for defense contractors. With the publication of the final 48 CFR Acquisition Rule (DFARS 252.204-7021) effective November 2025 and the CMMC Program Rule (32 CFR Part 170) effective December 2024, new, enforceable requirements firmly establish how noncompliance is handled. This article summarizes the latest updates on conditional certification, remedial actions, and contract impacts so contractors can confidently navigate assessment outcomes and maintain eligibility for DoD contracts.
In brief, contractors who nearly meet CMMC requirements can obtain Conditional Certification but must complete remediation tasks, or POA&Ms, within 180 days to avoid losing certification and contract opportunities. Read on to understand the workflows, enforcement mechanisms, and best practices for corrective actions under this updated framework.
What Happens When a Contractor Fails a CMMC Assessment?
When a contractor does not fully meet CMMC standards, the final rule creates a more nuanced path than outright failure. Instead, contractors can receive a Conditional Certification if at least 80 percent of required controls are implemented. This status allows them to continue contract performance while addressing remaining issues.
Assessment scores and findings are submitted to official repositories such as the Supplier Performance Risk System (SPRS) or the CMMC Enterprise Mission Assurance Support Service (eMASS). These systems reflect the contractor’s current posture and remediation progress for government oversight.
Conditional Certification Details
Requires meeting 80 percent of controls at CMMC Levels 2 or 3.
Remaining deficiencies must be captured in a Plan of Action and Milestones (POA&M).
All POA&M items must be addressed within 180 calendar days.
A POA&M Closeout Assessment validates completion for attaining Final Certification.
Critical controls cannot be deferred and must be implemented before conditional status can be granted.
"Conditional Certification gives contractors a clear runway to fix gaps without losing contract standing— but it is not indefinite."
Failure to complete remediation within this 180-day window results in certification revocation and contract ineligibility. Contracting officers may then terminate or decline contract renewals under DFARS provisions.
Understanding POA&M Requirements in the Final Rule
Non-critical controls only may be included in POA&Ms.
Contractors bear responsibility for timely remediation and transparent reporting.
Remediation progress and closure must be documented and tracked in SPRS or eMASS.
A formal closeout assessment is mandatory before Final Certification is granted.
Conditional Certification is a one-time status; it cannot be renewed or extended beyond 180 days.
Compliance with these requirements ensures contractors maintain standing as the DoD advances its cybersecurity standards across the defense industrial base.
How Enforcement Impacts Contract Eligibility
CMMC certification (or Conditional Certification) must be verified before contract awards.
Contracting officers will require current SPRS scores reflecting assessment results.
Contracts will demand proof that all POA&M items have been closed before renewal or exercising options.
Noncompliant contractors risk disqualification from bidding or termination of existing contracts.
This enforcement approach signals DoD’s commitment to stronger cybersecurity protections and greater accountability for defense contractors.
Common Causes for Conditional Certification and Remediation Strategies
| Root Cause | Example Deficiency | Typical Remediation |
|---|---|---|
| Root Cause: Incomplete Documentation | Example Deficiency: Missing policies or gaps in System Security Plan | Typical Remediation: Develop and formalize proper policies |
| Root Cause: Technical Control Gaps | Example Deficiency: Unpatched vulnerabilities or outdated software | Typical Remediation: Implement vulnerability scans and patching processes |
| Root Cause: Training/Awareness Deficiency | Example Deficiency: Personnel unaware of CUI handling protocols | Typical Remediation: Conduct comprehensive security training and tracking |
| Root Cause: Access Control Weakness | Example Deficiency: Lack of Multi-Factor Authentication (MFA) or improper access rights | Typical Remediation: Enforce MFA and conduct access reviews |
Understanding your specific gaps early helps prioritize corrective actions and efficiently close POA&Ms with proper documentation and review templates.
Maintaining Compliance Post Certification
Submit annual affirmations via SPRS confirming continued control effectiveness.
Maintain all documentation and evidence supporting their security posture for audits.
Prepare for triennial reassessments or additional assessments triggered by significant system changes by following expert guidance on mastering the CMMC assessment process.
Monitor control drift rigorously to avoid inadvertent noncompliance.
Proactive management helps sustain contract eligibility and builds trust with government customers.
Summary: Navigating Noncompliance with Confidence
| Scenario | Result |
|---|---|
| Scenario: Meeting 100 percent of controls | Result: Immediate Final Certification |
| Scenario: Meeting 80 percent or above | Result: Conditional Certification + 180-day POA&M |
| Scenario: Failure to complete POA&Ms in 180 days | Result: Certification Revoked, Contract Ineligibility |
| Scenario: Failing assessment below 80 percent | Result: Not eligible for contract award |
Contractors should use Conditional Certification as an opportunity to remediate gaps quickly and secure their position in the DoD supply chain.
Frequently Asked Questions
Frequently Asked Questions
What distinguishes Conditional Certification from Final Certification?
Conditional Certification is a temporary status granted when most controls are met but minor gaps exist. Final Certification requires all controls to be fully implemented and validated through a closeout assessment.
Are all control deficiencies eligible for POA&Ms?
No. Critical controls like incident response and access management must be fixed immediately and cannot be postponed under a POA&M.
What happens if remediation cannot be completed in 180 days?
Conditional Certification automatically expires. The contractor must reassess and may lose eligibility for current or future contracts.
Can contractors keep working under Conditional Certification?
Yes, if the contract permits. However, failure to obtain Final Certification may lead to suspension or termination.
How should a contractor prepare for a POA&M closeout assessment?
Keep thorough evidence such as logs and policies, validate remediations internally, and coordinate scheduling with your C3PAO or DIBCAC assessor.
Take Action Now to Simplify CMMC Compliance
Navigating evolving CMMC requirements and enforcement can be daunting. The right tools make the journey manageable. Our CMMC Dashboard streamlines tracking of POA&Ms, evidence retention, and certification status, helping your team stay audit-ready and contract-eligible.
To streamline managing POA&Ms, track remediation deadlines, and monitor certification status effectively, consider signing up for our free trial of the CMMC Dashboard. This platform is designed specifically for defense contractors to maintain compliance and contract readiness with ease.
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Article authored by Jim Carlson, Co-Founder & CEO Updated October 2025 to reflect final DFARS and CMMC Program rules.
References:
- Department of Defense, 48 CFR / DFARS 252.204-7021 Acquisition Rule, Nov 2025
- Department of Defense, CMMC Program Rule 32 CFR Part 170, Dec 2024
- Supplier Performance Risk System (SPRS) Documentation
- CMMC Accreditation Body Guidance Documents