As 2025 comes to a close, the Defense Industrial Base is entering a new phase of cybersecurity accountability. CMMC Level 2 certification is no longer theoretical or aspirational. For many organizations, it is becoming an operational reality with real contractual consequences. 

As the CMMC Market Leader and a Lead Assessor for leading C3PAO A-LIGN, I’ve seen this shift firsthand through dozens of successful CMMC Level 2 assessments across a wide range of defense contractors. That concentration of activity has provided a clear and sometimes sobering view into what actually drives success, where organizations consistently struggle, and which patterns are emerging as we approach 2026.  

In this blog, I’ll share real-world lessons from the assessments I have experienced so far. These are not abstract best practices. They are lessons earned from real environments, real leadership teams, and real certification outcomes. 

Lesson one: Scope was treated as strategy, not documentation 

In every successful assessment, scoping decisions were made deliberately and early. Leaders treated scope not as a compliance form to complete, but as an architectural and operational decision that shaped everything that followed. 

Successful organizations invested the time to understand where Controlled Unclassified Information truly flowed, how responsibilities were divided between internal teams and service providers, and where separation and segmentation needed to be enforced. Those decisions were socialized across engineering, IT, security, and leadership long before assessment week began. 

Organizations that struggled often approached scope as paperwork: something to rush and guess so the “real work” could start. That mindset consistently led to confusion, rework, or unexpected exposure during assessment activities. 

As certification activity accelerates, assessment boundary clarity and scoping are proving to be one of the strongest predictors of readiness. 

Tip: Take time to get your scope rock solid, everything flows from that foundation. 

Lesson two: Documentation reflected reality, not aspiration 

None of the organizations that passed had perfect documentation. What they did have was documentation that matched how their environments operated. 

System Security Plans described real processes, real enforcement, clear ownership, and current system behavior. The documents were not overly polished, but they were accurate. That mattered more than volume or formatting. 

When organizations encountered difficulty, it was usually because documentation described how the system should  work rather than how it operated in practice. Those gaps surfaced quickly when validation began. 

As we move into 2026, documentation quality will increasingly be defined by alignment with reality, not by length or complexity. I recommend following this rule:  

Tip: Say what you do, do what you say.  

Lesson three: Evidence was managed as an operational discipline 

There is a key indicator across all my recent successful assessments: evidence of control maturity emerged as one of the clearest differentiators of readiness.  

Organizations that performed well treated evidence as part of ongoing operations, not as a task reserved for assessment week. Artifacts were mapped to requirements ahead of time, validated for currency, and organized in a way that reduced ambiguity for both internal teams and assessors. 

That preparation paid dividends. Assessments moved more efficiently, discussions stayed focused on substance, and friction was significantly reduced. 

By contrast, evidence chaos — incomplete artifacts, unclear ownership, or last-minute assembly — remained one of the most consistent predictors of assessment difficulty. 

Tip: Use your self-assessment processes to validate control evidence before your external assessment. Be familiar with what you used to validate your control performance.  

Lesson four: Shared responsibility was clearly understood and documented 

Cloud adoption and managed services are now the norm across the DIB, which makes shared responsibility one of the most misunderstood areas of CMMC readiness. 

Successful organizations did not rely on assumptions. They documented which controls were inherited, which responsibilities remained internal, and what their service providers were accountable for delivering. More importantly, they could demonstrate those responsibilities through evidence and ongoing management. 

This clarity extended to identity, boundary protection, logging, monitoring, and incident response. When shared responsibility was explicit and validated, assessments proceeded smoothly. When it was vague, gaps and confusion emerged quickly. 

In 2026, organizations that proactively close the seams between vendors, platforms, and internal operations will be far better positioned for certification. 

Tip: Everyone relies on someone else, that’s the nature of our connected world. Understanding those relationships is key to your CMMC success.  

Lesson five: Leadership behaviors predicted success before any control was reviewed 

Perhaps the most consistent insight from recent assessments had little to do with technology and everything to do with leadership. 

In every successful engagement, leadership behaviors and engagement were visible from the start. Roles were clear. Teams were prepared. Discussions were calm, structured, and grounded in fact. Executives understood their environment well enough to speak confidently about scope, ownership, teams, and priorities. 

CMMC Level 2 is often framed as a technical standard. In practice, it functions just as much as a leadership and governance standard. Organizations that treated CMMC as a one-time project struggled. Those that treated it as a sustained readiness discipline succeeded. 

Tip: Leadership buy-in and support is perhaps the biggest and most consistent predictor of success.   

Looking ahead: Modernization will shape CMMC success in 2026 

Beyond these five lessons, a broader shift is becoming clear. Organizations that move faster and with less friction are modernizing how to approach compliance. 

We are seeing early adoption of machine-readable documentation through OSCAL, reduced reliance on screenshots, increased use of configuration telemetry, stronger identity governance, and greater automation in evidence collection. These capabilities are not yet universal, but the trajectory is clear. 

As certification activity scales, maturity and modernization will increasingly separate organizations that struggle from those that sustain readiness. 

Final thought 

The mission continues: CMMC success is not a milestone; it’s a mindset. As we head into 2026, CMMC readiness will belong to organizations that treat compliance as an operational discipline, embrace modernization, and lead with clarity and collaboration. Ready to begin your journey in CMMC compliance? Reach out today to learn more.