The road to achieving CMMC Level 2 compliance can feel like navigating a high-stakes road map filled with checkpoints, where a single misstep can derail the entire journey. Organizations frequently overlook the big picture, but scoping errors quietly pause progress. In this article, I delve further into the blunders that hinder CMMC Level 2 requirements and what these blunders truly indicate in terms of certification readiness.
Misclassification of CUI Leading to Scope Expansion
Scope creep is a resultant over extrapolation of the CUI. Controlled Unclassified Information (CUI) is one of the most misjudged and misclassified forms of organizational data. Subsets of CUI lie entrenched in engineering documents or procurement records that are not appropriately flagged. As a result, organizations misjudge their CMMC boundaries.
This misstep results in more systems, people, and processes falling into the CMMC level 2 compliance zone. Obtaining the services of a Registered Provider Organization (CMMC RPO) or C3PAO mitigates oversights in CUI flow and retains the assessment. They ensure minimal net casting, casting only what is necessary to eliminate netting everything, regardless of context.
Insufficient Network Segmentation Driving Assessment Complexity
Inadequate segmentation complicates efforts to isolate and safeguard CUI. Often, a flat network architecture allows the CUI to traverse through systems that do not require interaction with it. This compels those systems to be included in the CMMC assessment, thereby increasing documentation and security requirements across the board.
Appropriate segmentation—through VLANs, subnetting, or physical separation—helps shrink the assessment boundary and protects sensitive data far more effectively. Without it, your network becomes a single zone of responsibility under CMMC compliance requirements, which slows down audits, increases the number of controls in scope, and makes compliance a much larger lift than it needs to be.
Overlooking Third-party Systems Affecting CMMC Boundaries
Businesses often rely on third-party outsourcing for human resources, finance, or managed IT services without considering how those services interact with CUI. If a contractor or vendor, or a certain cloud-based application, stores or processes sensitive data, then they are included in the assessment, whether you intend them to or not. Not accounting for these third-party systems can significantly delay the process when getting the business compliant later on.
The situation becomes worse when third-party access is inadequately documented. Any unmanaged access to CUI may result in noncompliance. In order to safeguard against this, businesses need to manage third-party access and determine whether the providers are either out of scope or meet CMMC Level 2 verification themselves. This involves engaging a qualified C3PAO or CMMC RPO to set the appropriate boundaries so you do not get caught off guard during the assessment.
Neglecting Physical Security Measures Impacting Compliance Scope
World barriers matter alongside technological obstacles. Assessors will evaluate physical security measures protecting access to systems containing CUI. Forgetting to close doors, monitoring access control systems, and placing servers in unlocked rooms can all increase your compliance gap.
What renders this error so damaging is how unnoticed it can be, particularly by organizations with remote or hybrid work models. Even with standards-compliant digital systems in place, assessors will evaluate if the physical environment enables secure operation. Access control and visitor logs, as well as locked hardware cabinets, can maintain a precise and unblemished scope devoid of secure operation failures.
Incomplete Documentation of Virtual Assets Causing Scope Ambiguity
A portion of the modern IT infrastructure comprises virtual servers, remote systems, and cloud-based silos, yet these assets are often undocumented. These systems, similar to physical systems, can store, process, or transmit CUI. If these systems are not accurately mapped or are omitted from asset inventories, the scope of the assessment becomes ambiguous.
Assessors want to understand the ecosystem in which the CUI flows; this includes its storage locations, containers, and even ephemeral cloud instances. In the absence of this, progress on reaching the CMMC Level 2 milestone stalls due to a lack of clarity. Businesses are required to identify, label, and document all virtual assets pertaining to the circulation of CUI because ambiguity in control frameworks delays progress.
Underestimating Endpoint Device Inclusion Complicating Assessments
Ignoring Compliance Assessment Inclusions Concerning Devices Beyond the Perimeter
Devices such as printers, laptops, and smartphones can interact with CUI, which rapidly broadens your CMMC scope. It is common to presume that protection is only required on designated workstations or servers, but during regular operational activities, mobile and remote endpoints frequently access or store CUI. Neglecting these devices in scoping calculations risks creating an unaddressed gap in the compliance strategy.
Inadequate attention to endpoints results in incomplete assessments as a direct consequence of reactive security fixes. Organizations working toward CMMC Level 2 compliance must ensure that all endpoints interfacing with CUI are fortified with appropriate safeguards: encryption, multi-factor authentication, detection and response systems, and endpoint alerting mechanisms, as well as routine patching. Clear audit outcomes are more likely when strong controls are applied to scoped devices. This helps define stronger perimeters and avoids surprises during mid-audit interactions.
Ignoring Cloud Service Providers’ Shared Responsibility in Scope Determination
Cloud services provide additional flexibility but come with a shared responsibility model, which is often misunderstood. Organizations scope security efforts assuming that the cloud service provider addresses all requirements, and that is far from the truth, as both parties bear distinct responsibilities. Should you host CUI in the cloud, it is your organization’s responsibility to comply with CMMC regulations relevant to access, monitoring, and encryption, including key controls.
Leaving the shared boundary undefined results in gaps during the audit. As the entity assigning compliance responsibilities for the shared environment, you need to illustrate who manages what, detail the compliance framework, and define the system boundaries that the assessment applies to. Engaging with CMMC RPOs or C3PAOs earlier in the process helps correctly delineate cloud responsibilities and sidesteps costly misunderstandings down the road.
