We're ready for our self-assessment."
We're hearing this more and more from defense contractors. They've bought security tools. They've written policies. They've checked the boxes.
But here's the problem: being ready and proving you're ready are two different things.
Phase 1 lets you assess yourself. But Phase 2 starts in 11 months. That's when third-party assessors check your work.
Many contractors are learning this the hard way. There's a big gap between "we do cybersecurity" and "we can prove we meet the requirements."
If you can't prove it, you can't pass.
What Assessors Actually Check
Failed assessments mean lost contracts.
Restarting after you fail wastes months of work. Prime contractors lose trust in subs who aren't ready.
Here's the truth: Assessors don't care about your budget or your plans. They only care about evidence.
They check if your controls actually work—not if you plan to make them work.
They verify your documentation matches what you actually do—not what you wish you did.
They confirm your team knows why controls matter—not just that controls exist.
Good news: You can build real readiness when you know what assessors look for.
It starts with four pillars.
The Four Pillars of Assessment Readiness

Pillar 1: Controls That Actually Work
What it means: You can prove every control works right now—not someday, but today.
Many companies buy security tools and write policies. But they can't show the controls are actually running.
What assessors want to see:
- Access controls enforced every day
- Incident response procedures that have been tested
- System settings that match your documents
- Controls you can demonstrate, not just describe
Bottom line: If a control is "in progress" or "partially done," it doesn't count.
Pillar 2: Documentation That Matches Reality
What it means: Your documents describe what you actually do—not what you hope to do.
This is where most companies fail. They write beautiful policies that describe perfect processes. Then an assessor watches their team and sees something completely different.
What assessors want to see:
- Your Security Plan describes your real environment
- Your policies match how your team actually works
- When employees explain their job, it matches what's written
- No gaps between what you say and what you do
Bottom line: If your documents don't match reality, both fail the assessment.
Pillar 3: Your Team Understands Why
What it means: Your employees know why controls exist—not just that they exist.
CMMC isn't just a tech problem. It's a people problem.
The best security tools fail if your team doesn't understand their role. When security becomes "IT's job" instead of everyone's job, controls fall apart.
What assessors want to see:
- Employees understand how their actions affect security
- People know why processes exist, not just that they must follow them
- When employees make decisions, they choose the secure option
- Security is part of your culture, not just your policy manual
Bottom line: Controls work when people understand them. They fail when people don't.
Pillar 4: Evidence That Holds Up
What it means: Your proof would satisfy someone who's never seen your company before.
Here's the trap: You assess yourself in Phase 1. You know your own environment. Your evidence makes sense to you.
But Phase 2 brings outside assessors. They don't know your company. If your evidence only makes sense to insiders, it won't pass.
What assessors want to see:
- Documents clear enough for outsiders to understand
- Evidence that's specific and dated
- Proof of ongoing practice—not one-time events
- Records that tell a complete story
Bottom line: If you have to explain your evidence, it's not good enough.
Moving Forward
"But we already did our self-assessment."
That's good. Self-assessment is valuable practice.
But it's just practice. Phase 2 brings real validation in November 2026.
Companies treating self-assessment as a dress rehearsal will be ready for Phase 2. Companies treating it as a checkbox are setting themselves up to fail.
Assessment readiness isn't about being perfect.
It's about proving you can work within the standards you claim to meet.
That's the difference between passing and failing.
Ready to see where you really stand?
We help defense contractors assess their true readiness and build a path to Phase 2 certification.
Contact Prescott to evaluate your readiness.
Frequently Asked Questions
Most companies need 9-12 months to build complete readiness. This includes:
- Putting all 110 NIST controls in place
- Creating documents that match reality
- Training your team
- Building evidence that assessors will accept
Companies with strong security already may move faster. Companies starting from scratch should plan for the full year.
Start early so you're not rushing to meet deadlines.
Yes. This happens often.
Self-assessment lets you grade yourself. You might be too optimistic about weak evidence or controls that aren't fully working.
C3PAO assessors look at everything closely. They examine evidence in detail. They watch controls in action. They interview your team.
Many companies find gaps during C3PAO assessment that they missed during self-assessment.
This is why Phase 1 is valuable, it helps you find and fix gaps before Phase 2.
For CMMC Level 2, you must have all 110 NIST controls working to pass.
There is one exception: Plans of Action and Milestones (POA&Ms). These let you address certain gaps within 180 days after conditional certification.
But
- Not all controls qualify for POA&Ms
- The DoD limits how you can use them
- Assessors apply them very strictly
Don't plan on POA&Ms as your strategy. Plan to have everything working before assessment.
Phase 1 (now through November 2026):
- You assess yourself
- You post your score in SPRS
- No outside validation required
Phase 2 (starting November 2026):
- Independent assessors validate your compliance
- They review all your evidence
- They observe your systems
- They interview your employees
- They apply strict, consistent standards
The requirements are the same. The level of scrutiny is much higher in Phase 2.
Scores you post in Phase 1 will face validation when you get C3PAO certified in Phase 2.
Assessors want objective evidence that proves ongoing compliance:
They look for:
- System settings showing controls are enforced
- Logs proving you monitor and respond
- Records of security procedures being followed
- Training records showing employee awareness
- Tested incident response procedures
- Access control records showing proper authorization
Evidence must be:
- Specific: Shows exactly what you did
- Dated: Proves current practice
- Consistent: Shows ongoing compliance, not isolated examples
What doesn't work:
- Generic or old evidence
- Policies without proof you follow them
- Documents that don't match what assessors observe
