
CMMC by the Numbers: The Compliance Crisis No One's Talking About
1 Jan 2026
431 out of 80,000.
That's how many defense contractors have achieved Level 2 CMMC certification as of October 2025, according to the CyberAB Town Hall. Let me say that differently: 0.54% of companies that need certification actually have it, and the mandatory deadline is 12 months away.
We pulled data from DOD reports, CyberAB town halls, and government contracting databases to understand what's actually happening with CMMC compliance. The numbers tell a story that most VARs and government contractors aren't hearing from the "get compliant now" marketing emails.
The Supply Crisis in Three Numbers
93 : 80,000 : 287
Here's what those mean:
93 authorized C3PAOs (as of December 2025 CyberAB Town Hall)
80,000 companies that need Level 2 certification (DOD estimate via Federal News Network, July 2025)
287 assessments per C3PAO per year to meet the three-year recertification cycle
That's 1.1 assessments per C3PAO per business day. Every single business day. For the next three years.
And that's assuming zero growth in the defense industrial base, no delays, no failed assessments requiring re-work, and perfect distribution of assessment load.
How We Got Here
The Cyber AB has been steadily authorizing C3PAOs:
2022: 16 C3PAOs
2023: 48 C3PAOs
July 2025: 74 C3PAOs
December 2025: 93 C3PAOs
That's encouraging growth. They've nearly doubled the assessor pool in two years. But here's the
problem:
"The DOD estimates that of the approximately 300,000 companies in the defense industrial base, 80,000 must qualify for CMMC Level 2, with most requiring third-party assessments conducted by a CMMC Third-Party Assessment Organization (C3PAO)."
— Deltek Survey, July 2025
Even with 93 authorized C3PAOs, many are already booked 6-12 months out. The DOD projects only 135 C3PAO assessments will occur in Year 1 (source: GovConWire, January 2026).
The Timeline Reality Check
November 10, 2025 – CMMC requirements began appearing in new DOD solicitations (self-assessment phase)
November 10, 2026 – Phase 2 begins. Third-party C3PAO assessments become mandatory for contract awards.
Preparation time required: 6-12 months average (source: Summit7, multiple industry reports)
If you're reading this in January 2026 and haven't started, you're already cutting it close for Phase 2 contracts.
The Cost Reality
Direct C3PAO assessment fees: $35,000 - $75,000
Total compliance costs (including remediation, prep, documentation): $25,000 - $100,000+ for small defense contractors
But here's what those estimates don't include:
Time spent preparing for assessment (internal labor costs)
Failed assessments requiring re-work
Opportunity cost of delayed contract awards
Premium pricing from booked-out C3PAOs
One contractor quoted in GovConWire noted: "C3PAO fees typically run $40,000 to $60,000, and if your assessment is halted because controls are not fully implemented or documentation is incomplete, you will likely pay again for a second assessment."
What Nobody's Saying About Quoting Systems
Here's where it gets interesting for VARs: How you generate quotes directly impacts your CMMC compliance.
When the C3PAO assessor asks "show me how you handle CUI in your quote generation
process," what are you going to show them?
Excel spreadsheets emailed around?
PDFs with technical specs attached to Gmail?
Customer pricing data in shared drives?
Quote history in Salesforce with no encryption controls?
Your quoting process touches CUI constantly:
Customer technical requirements
Pricing strategies for government contracts
Part numbers and specifications
Previous contract data
Communications with government customers
If your quote workflow doesn't have proper access controls, encryption, audit trails, and CUI handling procedures documented, you're adding assessment objectives to your remediation list.
The Readiness Gap
"As of the October CyberAB Town Hall, only 431 organizations had achieved a final CMMC Level 2 certification—representing just 0.5% of the roughly 80,000 companies the DoD estimates will require Level 2."
— Secureframe, November 2025
An October 2025 CyberSheath report found that only 1% of Defense Industrial Base organizations felt fully prepared for CMMC assessments.
Translation: 99% of companies are either:
Not ready and know it
Not ready and don't know it yet
Think they're ready but haven't been assessed
What This Means For Your Business
If you're a prime contractor:
Your subcontractors need Level 2 certification
Their compliance gaps become your supply chain risk
You're competing for the same limited C3PAO slots they are
If you're a subcontractor:
Primes are already asking for SPRS scores and compliance roadmaps
Waiting until it's contractually required means you're last in line
Early certification = competitive advantage in sub selection
If you're a VAR serving government customers:
Every quote you generate potentially involves CUI
Your quoting system is part of your assessment scope
"We handle it manually" is not a passing answer
What To Do Right Now
Check your current SPRS score (if you already self-assessed under DFARS 7012)
Audit your quote generation process for CUI handling gaps
Get on a C3PAO's calendar for a readiness assessment (not the full assessment yet)
Document everything – especially how quotes move through your organization
The companies that get certified in 2026 aren't the ones with perfect security. They're the ones who started preparing in 2025.
Data sources: CyberAB Town Hall (December 2025, October 2025), Federal News Network, Deltek Industry Survey, DOD CMMC Program Rule, GovConWire, Summit7, Secureframe, GetCybr, RidgeIT, ISI Defense. All statistics are from publicly available government and industry reports published between July 2025 and January 2026.

Cyrus Calloway
VP of Business Development at Virtual Dojo, helping government contractors and VARs win more deals.
