Earning a CMMC Level 2 certification is a significant achievement. Maintaining it across the full three-year assessment cycle, and being able to truthfully affirm compliance every year, is a different and more demanding challenge.

C3PAOs conducting assessments and practitioners supporting organizations through their compliance journey are consistent on one point: the organizations most at risk of failing their second assessment aren't the ones that did the least work to earn their first certification. They're often the ones who put in a herculean effort to pass that first assessment, and then stopped treating cybersecurity as an ongoing discipline once the assessor left.

This article covers what continuous CMMC compliance actually requires, using insights from actual C3PAOs and consultants so you’re prepared for the next wave of enforcement. Keep reading for the most common breakdown points between assessments, and practical steps for building the operational framework that makes annual affirmations defensible.

Why maintaining CMMC compliance is harder than getting certified

The first certification push has a forcing function: a deadline, an assessor, a clear pass/fail outcome upon which contract eligibility hinges. Organizations respond to that forcing function. They bring in consultants, they dedicate internal resources, they get leadership involved, and they get across the finish line.

Three years later, the board has moved on to other priorities. The consultants are gone. The person who was the institutional champion for the program may have left. The documentation that once reflected reality has started to drift from it.

Matt Gilbert, Principal at Baker Tilly and member of the original CMMC assessment methodology working group, shared a direct prediction at the Secureframe National Cybersecurity Summit 2026: second-round assessments are going to have higher failure rates than first-round assessments, specifically because of this dynamic.

Tommy Kromer, Practice Manager at AWS Security Assurance Services, described the underlying failure mode: most organizations are treating CMMC the way a student treats an exam they plan to cram for. 

"You didn't really learn, you just crammed for the test, you got a good score, and then three weeks from now you forgot everything you crammed for. And that drift is, at that point, almost willful,” he explained, “because you don't treat it as a lifestyle. It's not a culture change, it was getting ready for an exam."

The question that matters for many organizations now isn't "can we pass our second assessment?" It's "were we actually compliant the full three years in between?" That's a much harder question to answer confidently, and the one that assessors are going to start asking. For organizations that don't treat CMMC compliance as a continuous discipline, the honest answer is probably no.

How CMMC compliance breaks down between assessments

Compliance programs don't usually break overnight. They fail gradually. Here’s common issues that organizations face when trying to maintain their CMMC program.

Controls drift without anyone noticing

Kromer described the pattern of “slow rot”:

• Access controls allow more and more exceptions. For example, a service account gets more permission than it should for five days, and five days becomes ninety days, and ninety days becomes permanent. 
• No one updates the documentation to reflect the change.
• The SSP stops describing what the environment actually looks like.

Physical or organizational changes compound this. A new office opens. A key tool gets upgraded to a version that isn't FedRAMP Moderate Equivalent. An integration gets added to a system inside the assessed boundary without a formal change review. 

Each change individually seems minor. Together they can add up to an environment that looks significantly different from what was assessed,  without the organization realizing it.

Compliance hinges on one champion

Kromer identified what he sees as the biggest single driver of compliance decay: the loss of a security champion.

"When that champion leaves, the culture goes with it. Whoever picks up the documentation finds instructions that describe what was done, but not why. Without understanding the intent behind the controls, the new owner can't make good judgments about what matters and what doesn't."

This is a structural problem that pure documentation can't solve. If the documentation describes procedures but doesn't capture the reasoning behind them, new personnel may follow CMMC controls when they can and deviate when they have to do their job. This opens up compliance gaps.

The annual affirmation becomes a rubber stamp

CMMC requires a senior official to affirm annually that the organization remains in compliance. This is more than paperwork. It’s accountability: a named individual attesting, under penalty of potential False Claims Act liability, that the certification still reflects reality.

In practice however, many organizations are treating the affirmation as an administrative task: a document needs to be signed, compliance is affirmed, and the cycle continues without taking the time to reassess your organization’s current cybersecurity posture.

Gilbert described the risk directly: the affirmation carries legal weight. A senior official making that affirmation without a genuine basis for it—meaning, without evidence that the controls were tested, that changes were reviewed, that the SSP still reflects the environment—is taking on personal liability they may not understand.

His recommendation: the affirmation should be the culmination of a year of active compliance management, not the starting gun for a last-minute review.

5 Must-dos to maintain CMMC compliance

Here are five things organizations must do to maintain CMMC compliance over time, according to C3PAOs and consultants who have helped organizations prepare for and complete real assessments:

1. Test controls continuously, not just before assessments

Gilbert's practical prescription: divide the 110 NIST 800-171 Rev 2 requirements across 12 months and test a handful each month. Even a manual check of "are we still doing this?" is far better than letting controls go untested for 35 months between assessments, he explained. But automating where possible can simplify the process and get you closer to true continuous monitoring.

The goal is that by the time a senior official makes their annual affirmation, they have actual evidence from throughout the year, not just a memory of what was in place the day the assessor left.

This also builds institutional knowledge. Monthly reviews force someone to engage with the controls regularly, understand what they're testing for, and catch drift before it compounds.

2. Build and maintain a framework for significant change decisions

One of the most consequential gaps in many organizations' compliance programs is the absence of a functioning process for evaluating whether a given change is "significant" under CMMC requirements.

First defined in the latest DoD CMMC FAQ revision, a significant change is one that materially alters the security posture, architecture, or scope of the assessed environment and therefore requires coordination with the C3PAO and potentially a reassessment. Not every change meets this threshold: routine patching, onboarding users into an existing environment, and hardware replacements that maintain the same configuration are generally not significant.

But organizations without an explicit framework for making this determination are effectively making these calls informally, without documentation, with no way to defend the decision later if it's questioned.

Marci Womack, Managing Director at Shellman and member of the CyberAB C3PAO Advisory Council, described what good looks like: "Organizations should have an internal framework for evaluating whether any given change is significant, and that framework should be baked into how changes are reviewed.

It should also be baked into an organization’s annual self-assessment between C3PAO assessments to provide more assurance to the authorizing official during their annual affirmations. The goal is to ensure the AO can say, “I am confident in what I'm affirming here.” Womach said.

Practical components of a significant change framework:

• A defined list of change types that are presumptively significant (new cloud service providers, architectural redesigns, new business units handling CUI, new locations)
• A formal security impact analysis process for changes that might be significant
• Documentation of the analysis and decision for each reviewed change
• Review cadence that ensures changes are captured promptly, not retrospectively

3. Keep the SSP current 

The System Security Plan (SSP) should describe how the environment actually works, not how it should work, which means it must be updated as the environment changes. In practice, many organizations write their SSP during the certification push and don't update it again until the next assessment cycle begins.

Kromer described the consequence: documentation that was accurate on the day the assessor left will increasingly diverge from reality as changes accumulate. When the next assessment arrives, the gap between the SSP and the actual environment becomes both an assessment failure risk and evidence that change management was documented on paper, but not functioning in practice.

The fix is treating SSP updates as a standard part of change management. Instead of a separate effort, it should be part of the review process that evaluates whether a change is significant. If a change is reviewed and found not significant, document that. If it is significant and requires reassessment, update the SSP to reflect what changed. This ensures the SSP is an operating record, not an assessment artifact. 

4. Protect against key-person dependency

If continuous compliance depends on a single individual who champions the program, the program is one resignation or promotion away from losing its operational foundation.

Practical steps to avoid this are:

• cross-training more than one person on CMMC obligations
• document the reasoning behind key decisions (not just the decisions themselves)
• ensuring that whoever owns the CMMC program has a meaningful ongoing role with the controls rather than occasional involvement

Having a CMMC platform in place that automates assessment-readiness and continuous compliance can also bolster the resilience of your CMMC and overall cybersecurity program. 

5. Put the culture in place, not just the controls

Every C3PAO that spoke at the Summit returned to culture as the foundation that everything else rests on.

Womack's single-sentence takeaway for organizations was to “live and breathe what you say you're doing, and make it part of every day."

According to Kromer, a culture of security should be put in place before you even start implementing controls. “Culture isn't even an easy point-in-time thing. It has to be driven continuously so that it gets ingrained over time."

What this means practically: CMMC can't be owned by a single person or team, or remain invisible to the rest of the organization. The people who generate CUI, who manage systems in the assessed boundary, who make purchasing decisions that could introduce new tools all need to understand their role in that culture. This doesn’t mean they need to become security experts. It means they need to know when to ask a question before taking an action that might affect your organization’s compliance posture.