Preparing for the Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0) can feel like a maze of controls, assessments, and documentation. Yet some failure points stand out clearly to assessors from the very start. Understanding these early red flags helps organizations aim for a smoother path when working with a C3PAO and meet the rigorous CMMC compliance requirements.
Missing Policy Documents That Should Outline Required Security Practices
Auditors expect documented policies that map directly to the applicable CMMC Controls and the CMMC level 1 requirements or CMMC level 2 requirements. Without a formal policy for access control, incident response, or configuration management, assessors interpret the absence as a lack of governance. That gap makes proceeding with a valid assessment risky because the rules say controls must be implemented correctly, operating as intended, and producing the desired outcome.
Such missing policy housing often marks one of the common CMMC challenges early in the process: incomplete documentation. Within a CMMC Pre Assessment phase many organizations discover that their system security plan (SSP) and other foundational documents either reference outdated workflows or only cover a fraction of the environment.
Unclear Access Controls with No Proof of User Permission Reviews
When user permissions, roles, and access reviews aren’t documented, auditors view that as a critical control gap. The organization must show how users are granted or revoked rights—especially where CUI (Controlled Unclassified Information) is involved. Without periodic reviews of access permissions, assessors suspect possible exploitation, which undermines CMMC level 2 compliance.
Assessors often probe deeper by asking to see logs of user permission changes, review summaries, or evidence of quarterly access audits. Failures typically trace back to assumptions that the IT team who has access, rather than treating access control as a formal control process.
Incomplete Asset Inventories That Leave Systems Unaccounted for
A thorough inventory of systems handling CUI is foundational according to the CMMC scoping guide. If an organization cannot demonstrate it has accounted for every asset—endpoints, mobile devices, cloud hosts, network segments—it invites questions about unknown exposures. The assessment guide for Level 2 emphasizes defining the CMMC Assessment Scope so that all assets are evaluated.
What often happens is that organizations begin their assessments without updated inventories or segments outside in-scope are overlooked. In a real audit, these omissions become immediate red flags—because undocumented assets or systems mean undocumented controls and possibly unmanaged risk, which the auditor needs to evaluate.
Weak Password Rules That Fail to Meet Baseline Security Standards
Password policies remain one of the simplest but most frequently ignored aspects of compliance. When requirements for strength, expiration, reuse restrictions, or account lockout aren’t enforced and documented, auditors quickly highlight the deficiency. Weak password controls relate to basic credential management, one of the top reasons for audit failure.
Auditors expect the organization to tie its password policy directly into the CMMC level 1 requirements or level 2 requirements when applicable. If the policy exists but logs or records show administrative accounts or generic accounts are still widely used, this signals the controls are not operating as intended—which triggers further scrutiny.
Lax Logging Activity with Little Evidence of Monitoring
For an effective assessment, evidence of log collection, review, and monitoring is critical. Beyond just “yes logs exist,” auditors check for historical review actions, alerts issued, responses documented, and change-management events captured. This ties into the broader expectation of continuous monitoring, a frequently cited deficiency in CMMC compliance consulting engagements.
What asks the auditor isn’t only “are logs collected,” but “are they reviewed and acted upon?” If the logs show nothing or evidence cannot be produced, auditors mark the control as NOT MET, which jeopardizes passing.
Unpatched Systems Showing Long Gaps in Update History
Control implementation under CMMC level 2 requirements expects systems that are regularly maintained—patches applied, vulnerabilities tracked, configuration baselines updated. Where there are long gaps in updates, the assessor flags this as a missing control operation. It signals that although policies may say “updates will be applied,” operational proof is missing.
This gap becomes more acute where CUI systems are concerned or when the inventory and access controls reveal systems outside normal maintenance windows. The audit effort then turns into explaining why systems remained unpatched—something many organizations wish they’d caught in their own readiness efforts.
Multi-factor Authentication Absent on Critical Accounts
Multi-factor authentication (MFA) is increasingly expected even for Level 1 or Level 2 environments, especially where remote access or administrative roles exist. If a contractor cannot provide evidence that key accounts are protected by MFA, auditors see it as insufficient access control and expect corrective items in the plan of action and milestones (POA&M). This missing MFA control becomes a red flag especially during the Intro to CMMC assessment stage or early interaction with a C3PAO. Auditors will ask for logs, configuration evidence, and implementation status. Absence of these items complicates the assessment and raises questions about the overall control environment.
Inconsistent Training Records for Staff Handling Sensitive Data
Human factors matter. If employees who handle CUI don’t have documented training, role-based tasks, or refresher courses, auditors view that as a weak link in the compliance chain. The CMMC compliance requirements include training and awareness as part of the broader control set. Assessors often request training records, role-specific task completion, quiz logs, or proof of periodic refreshers. When records are missing, incomplete, or generic (e.g., “completed 30-minute video”), the auditor registers a deficiency under personnel controls. That deficiency then extends to remediation planning and can delay certification.
For contractors looking to avoid these audit-level shocks and better prepare for a formal review with a C3PAO, it is wise to engage with qualified CMMC consultants who specialize in compliance consulting and government security consulting. In such engagements, MAD Security delivers systematic gap analyses, evidence collection frameworks, and remediation planning aligned with the assessment guide and the CMMC scoping guide.
