CMMC Level 2 Assessment Cost: DoD Puts the C3PAO Fee at $31,234 to $52,056, and the Third-Party Mandate Is Suspended
As of November 5, 2026, the CMMC Level 2 assessment cost in DoD’s own rule is $37,196 to $48,827 over three years for a self-assessment and $104,670 to $117,768 with a C3PAO, of which the assessor’s fee is $31,234 to $52,056. Those figures exclude implementation. New C3PAO requirements have been suspended since July 13, 2026.
Estimate your cost from DoD’s unit figures
Only numbers DoD published. No vendor prices, no per-seat guesses. Change a box and the formula updates.
Default case: small entity, Level 2 (C3PAO), one scope, three years. Turn on JavaScript to change the inputs.
Not a quote, not legal advice. Actual C3PAO prices are set by each firm; check your solicitation and contracting officer for what applies to you.
DoD’s table: what each path costs, by phase and company size
These are the figures in Tables 9 and 10 of the regulatory impact analysis inside the October 15, 2024 final rule (89 FR 83178), with the C3PAO line separated using the rule’s own line items at 89 FR 83185 and 83186. They are per assessment of one contractor information system, in 2023 dollars.
| Line item | Small, Level 2 (Self) | Other, Level 2 (Self) | Small, Level 2 (C3PAO) | Other, Level 2 (C3PAO) |
|---|---|---|---|---|
| Plan and prepare | $14,426 | $18,015 | $20,699 | $26,264 |
| Conduct: company and ESP labor | $15,542 | $19,964 | $45,509 | $28,600 |
| C3PAO engagement | none | none | $31,234 | $52,056 |
| Report results | $2,851 | $2,712 | $2,851 | $2,712 |
| Affirmations (initial plus 2 annual) | $4,377 | $8,136 | $4,377 | $8,136 |
| Total across 3 years | $37,196 | $48,827 | $104,670 | $117,768 |
| Assessment plus first affirmation, as DoD states it | $34,277 | $43,403 | $101,752 | $112,345 |
| Outside ESP hours in the model | 88 | 0 | 176 | 0 |
| All modeled hours over 3 years | 176 | 488 | 454 | 906 |
Tables 9 and 10 print “Conduct” with the C3PAO engagement included: $76,743 (small) and $80,656 (other). Two stated assessment-plus-affirmation figures differ from the sum of their parts by $1 ($34,277 and $112,345), which DoD calls a “minor rounding difference” in the second case, and the estimator uses the sum. Hours are our sum of DoD’s line items.
Plan Conduct labor C3PAO fee Report 3 affirmations
Two things stand out once the fee is pulled apart. First, moving from self-assessed to C3PAO costs almost the same at either size, $67,474 or $68,941. Second, the small-entity model pays outsiders more for preparation than for the audit: 176 ESP hours worth $45,809 against 120 C3PAO hours worth $31,234. The rule’s reason is that “small entities are likely to outsource IT and cybersecurity to an External Service Provider”. On a Level 2 (Self), the 88 ESP hours are worth $22,905, or 62% of the total.
The labor rates DoD used
| Code | Role in Tables 12 and 13 | Rate per hour |
|---|---|---|
| MGMT5 | Director (CISO or CIO background) | $190.52 |
| MGMT2 | Manager, 5 to 7 years | $95.96 |
| IT4 | Staff IT specialist, 7 to 10 years cyber | $97.49 |
| IT4-SB | Staff IT specialist at a small entity | $86.24 |
| IT3 | Senior IT specialist, 5 to 7 years | $81.96 |
| IT2 | IT specialist, 2 to 5 years | $54.27 |
| IT1 | Associate IT specialist, 0 to 2 years | $36.32 |
| ESP / C3PAO | Cyber subject matter expert, outsourced rate with overhead, G and A, and profit | $260.28 |
89 FR 83180. In-house rates include a 30% factor for fringe and employee-related expenses. Small entities use MGMT5, IT4-SB and ESP only. DoD’s $260.28 can be set against the contract labor rates in our IT hourly rates report.
What the estimate leaves out
The rule says plainly that “cost estimates are not included for an entity to implement the CMMC Level 1 or 2 security requirements, maintain implementation of these existing security requirements, or remediate a plan of action for unimplemented requirements”. DoD’s reason is that DFARS 252.204-7012 has required NIST SP 800-171 since December 31, 2017. It also assumes “the OSA passes the assessment on the first attempt” and counts one information system per small entity. And DoD warns that its numbers are “representative of average assessment efforts not actual prices of C3PAO services available in the marketplace”.
The model does give a useful sanity test. Split evenly, both C3PAO profiles work out to 40 hours per assessor (120 hours across 3 people, 200 across 5). DoD’s Level 2 Assessment Guide lists 320 assessment objectives across the 110 requirements, by our count, so the budget is 22.5 team-minutes per objective at the small profile and 37.5 at the larger one, including planning and reporting.
One slip to know about: the reaffirmation line for other than small entities prints “IT4 for 8 hours” next to $1,560, but 8 hours at $97.49 is $780. The $2,712 annual figure only adds up at 16 hours, the number used in the same section’s reporting line, so we keep DoD’s dollar figure.
The 48 CFR acquisition rule is a different number
The September 10, 2025 DFARS rule (90 FR 43560) carries its own, far smaller estimate, and it should not be added to the figures above. DoD says that analysis “only includes a cost analysis of the contractual requirements to upload self-assessments and complete affirmations in SPRS”: 5 minutes each to post a score, affirm and retrieve identifiers, across an assumed average of 5 information systems. Its public cost is $38,580,316 a year at a 3% discount rate and $36,271,632 at 7%, over 10 years. The 32 CFR rule’s public cost is $3,989,182,374 a year at 7% over 20 years (Table 11). DoD’s Level 2 (C3PAO) line alone reaches $19.52 billion over its first 10 years (Table 22). Demand counts and assessor capacity are tracked in our CMMC certification statistics.
Market anecdotes, kept apart from DoD’s numbers
Third-party claims: not DoD figures, not verified by us
We collected no quotes and surveyed nobody. These are public statements on pages ranking for this query, read on November 5, 2026. In the top 10 for this query and one further search, we did not find a C3PAO that publishes a fixed list price. The Cyber AB marketplace forbids bots and was not scraped. Most of the sellers below also sell CMMC tools or services.
| Who, and when | What they say | Against DoD |
|---|---|---|
| IBSS (describes itself as a Certified C3PAO), LinkedIn article Sep 9, 2026 |
Assessment fee: $30,000 to $150,000. All-in: $75,000 to $300,000 first cycle. | Top of range is 4.8 times DoD’s small-entity fee and 2.9 times its larger-entity fee. |
| Paramify blog Undated, read Nov 5, 2026 |
C3PAO fee, Levels 2 and 3: $35,000 to $75,000; wider range $20,000 to $100,000+. All-in: $63,000 to $200,000+. | Typical top is 2.4 times DoD’s small-entity fee. Its floor is close to DoD’s $31,234. |
| Workstreet blog Jan 23, 2026 |
C3PAO fee: $30,000 to $75,000. All-in: $50,000 to $200,000+. | Same top as Paramify. Its floor is $1,234 below DoD’s small-entity fee. |
| PreVeil blog Aug 21, 2026, modified Sep 2, 2026 |
Re-assessment every 3 years: $15,000 to $50,000+. All-in: $75,000 to $300,000+. | Conflicts with DoD’s model, which prices every triennial re-assessment at the full $31,234 or $52,056. |
| Reddit r/GovernmentContracting, Google snippet only “1 year ago” per Google |
Audit fee: $20,000 to $50,000. All-in: 100k+ even for small businesses. | One commenter’s figure. We read Google’s snippet, not the thread. |
Blue bars are third-party claims. The thin line on Paramify is its wider range. Dashed red lines are DoD’s estimates.
Where the vendor numbers and DoD’s numbers disagree
- “$105,000 to $118,000” is not an assessment fee. It is DoD’s three-year, all-in number. cmmc.com lists it under “Assessment fees (per DoD estimates)”, PreVeil under “CMMC Assessment Fees by Level”, and Secureframe says “a Level 2 third-party assessment will cost” that amount (while noting that it includes affirmations). Yet DoD’s fee is 30% of that total for a small entity and 44% for a larger one.
- DoD’s small-entity fee sits at the bottom of the market claims. Three fee ranges start between $30,000 and $35,000, right beside DoD’s $31,234, and run to $75,000 or $150,000. That spread is 2.4 to 4.8 times DoD’s figure. Divide those prices by DoD’s hours and $35,000 for 120 hours implies $292 an hour, while $75,000 for 120 hours implies $625, against DoD’s $260.28. The rule leaves pricing open: “Market forces of supply and demand will determine C3PAO pricing”.
- Re-assessment discounts are not in DoD’s model. PreVeil budgets a three-year re-assessment at $15,000 to $50,000+. Workstreet says fees “will be similar” to the first. DoD agrees with Workstreet: in Table 21, Year 4’s 12,675 small-entity assessments are 12,293 new entities plus the 382 from Year 1 repeating, and the year’s $1,301,872,564 total matches the full $101,752 unit price within rounding. No certificate issued under the December 16, 2024 rule reaches its three-year mark before December 2027, so renewal pricing is still mostly theory.
- A figure attributed to DoD that we cannot find. IBSS writes that “According to Department of Defense estimates, the 3-year cost for small defense contractors averages $487,970”. That number appears nowhere in the text of the 2024 or 2025 final rules, or in Tables 9 and 10. DoD’s small-entity figure is $104,670, so the claim is 4.7 times larger.
- A second federal agency is far higher. The SBA’s July 13, 2026 release says “total compliance costs can reach approximately $593,800 per CMMC certification” for small firms needing third-party assessment and “about $388,600” for self-assessment: 5.7 and 10.4 times DoD’s three-year figures. These are not like-for-like, since DoD excludes implementation and SBA says “total”, but the release gives no method, so the gap cannot be reconciled from public text. The suspension memo itself now cites “prohibitive compliance costs”.
- All-in ranges measure something else. Paramify’s $63,000 to $200,000+, Workstreet’s $50,000 to $200,000+, PreVeil’s and IBSS’s $75,000 to $300,000 and a Medium post’s $150,000 to $400,000 over three years include remediation and tools that DoD excludes by design. They cannot be read as evidence that DoD miscounted the assessment.
- “Small” is not 500 employees in the rule. Vanta’s table labels DoD’s small-entity column “500 or fewer employees”. The rule’s footnote 38 points instead to “the small business criteria and size standards provided in 13 CFR 121.201”, with no flat headcount.
- Most top-ranking pages do not mention the suspension. Of the 8 top-10 pages we could read, 2 (Paramify and Secureframe) mention it. PreVeil (August 21, 2026) and IBSS (September 9, 2026) were published after it, and the text we could read does not mention it; PreVeil still says organizations handling CUI will need a C3PAO assessment every three years.
Searchers also ask about California and Reddit. DoD’s estimate has no geographic variable at all. IBSS claims West Coast contractors pay up to 28% more than Midwest ones, with no source we could check. The Reddit thread that ranks on page one says, in Google’s snippet, that “the certification audit itself can cost 20-50k”.
What triggers a C3PAO instead of a self-assessment
A company does not pick. Under 32 CFR 170.3(d), DoD program managers or requiring activities select the CMMC Status based on the information the contractor will handle, and under DFARS 204.7502 a contracting officer may not award to an offeror without a current status at the required level for every system that will touch FCI or CUI. The July 13, 2026 memo then narrowed the options to self-assessments.
The detail that changes a budget:
- Active solicitations and contracts. The attachment orders amendments “explicitly removing” C3PAO and DIBCAC requirements from active solicitations, and says contracting officers “are directed to remove them via modification” before the next option period or at the next scheduled administrative modification.
- Subcontractors. Under 170.23, FCI-only subs need Level 1 (Self), and CUI subs need at least Level 2 (Self), or Level 2 (C3PAO) when the prime contract requires it. With the C3PAO designation barred, that last branch has nothing to attach to on new DoW awards.
- Already certified. Under 170.17(a), a Level 2 (C3PAO) status also satisfies Level 1 (Self) and Level 2 (Self) for the same scope, so a current certificate still answers a self-assessment requirement if it is kept alive with annual affirmations.
- Choosing a C3PAO anyway. The rule’s preamble says companies “may elect to complete a self-assessment or pursue a certification assessment at any time”. FAQ C-A11 says paper-only CUI handlers need no third-party assessment but may elect one.
- DIBCAC carryover. Under 170.20, a perfect-score DIBCAC High assessment from before the rule’s effective date converts to Final Level 2 (C3PAO), valid three years from the original assessment date.
Dated status table
| Date | Event | Source |
|---|---|---|
| Oct 15, 2024 | CMMC Program final rule published | 89 FR 83092 |
| Dec 16, 2024 | 32 CFR part 170 takes effect | 89 FR 83092 |
| Sep 10, 2025 | DFARS acquisition rule published | 90 FR 43560 |
| Nov 10, 2025 | Phase 1 begins: Level 1 (Self) or Level 2 (Self), Level 2 (C3PAO) at DoD’s discretion | 32 CFR 170.3(e)(1) |
| Jul 13, 2026 | Phase 2 suspended, 60-day review and task force ordered, FAQ revised the same day | DoW release, CIO memos, FAQ revision history |
| Sep 11, 2026 | Task force report due (60 days). A September 21 law-firm update said it “has not yet been made public” | Covington, secondary |
| Nov 3, 2026 | eCFR currency date. Part 170’s source note lists only the 2024 rule, and 170.3(e) is unchanged | eCFR |
| Nov 5, 2026 | DoW CIO page still shows the suspension, no new guidance posted. Federal Register search for 2026 returns 2 documents mentioning CMMC, neither a CMMC rule | Our check |
| Nov 10, 2026 | Original Phase 2 date: Level 2 (C3PAO) as a condition of award. Suspended | 32 CFR 170.3(e)(2), DoW release |
| Nov 10, 2027 and 2028 | Original Phases 3 and 4. Held “until further notice” | 32 CFR 170.3(e)(3) and (4), CIO memo |
Enclave or whole network: what scope does to the bill
DoD’s cost tables have a size variable and no scope variable. Yet the rule says “the size and complexity of the network within the scope of the assessment impacts the costs as well”. So the honest estimator input is how many separately assessed scopes you have, plus which of DoD’s two team profiles fits. The preamble allows either route: a company “can achieve a specific CMMC Level for its entire enterprise network or an enclave(s)”.
Enclaves can shrink what is assessed, but they are not a free pass. A certificate “applies only to the assessed CMMC Assessment Scope”. An enclave can draw on enterprise controls, yet “it cannot inherit the enterprise certification”, and “Enclaves beyond the certified CMMC Assessment Scope must be assessed separately”. DoD’s scoping guide adds “There is no established metric for inherited implementations”, and all requirements inside the enclave must still be MET. Two FAQ answers help: encrypted CUI crossing enterprise network gear does not pull that gear into scope if the enclave is otherwise logically separated (F-A4), and an endpoint limited to keyboard, video and mouse with a VDI session is out of scope when configured that way (F-A1).
| Asset category, 170.19(c)(1) | What it is | What the assessor does |
|---|---|---|
| CUI Assets | Process, store or transmit CUI | Assess against all Level 2 requirements |
| Security Protection Assets | Provide security functions to the scope | Assess against the requirements relevant to those capabilities |
| Contractor Risk Managed Assets | Can, but are not intended to, handle CUI because of policy, procedure and practice | Review the SSP; a limited check is allowed that “shall not materially increase the assessment duration nor the assessment cost” |
| Specialized Assets | IoT, IIoT, OT, GFE, restricted systems, test equipment | Review the SSP; do not assess against other requirements |
| Out-of-Scope Assets | Cannot handle CUI and give no security protection to CUI Assets, or are physically or logically separated | None. The company must be ready to justify the category |
MSPs and ESPs: the 32 CFR 170.19 rules that decide your role
Under 170.4, an External Service Provider must have “CUI or Security Protection Data (e.g., log data, configuration data)” processed, stored or transmitted on its assets. If it has neither, it is not an ESP for CMMC purposes. Security Protection Data includes configuration data, log files, “data related to the configuration or vulnerability status of in-scope assets” and passwords. Read against that wording, a tool that stores patch status, EDR logs or admin credentials for a client’s scope is hard to place outside it.
| The provider handles | If it is a CSP | If it is not a CSP (a typical MSP) |
|---|---|---|
| CUI, with or without SPD | Must meet the FedRAMP requirements in DFARS 252.204-7012 | Services are in the client’s scope and assessed as part of its assessment |
| SPD, without CUI | Services are in the client’s scope, assessed as Security Protection Assets | Services are in the client’s scope, assessed as Security Protection Assets |
| Neither | Not an ESP | Not an ESP |
Table 4 to 32 CFR 170.19(c)(2)(i), paraphrased. Current to November 3, 2026.
| Common setup | What DoD says | Source |
|---|---|---|
| MSP hosts client CUI on a non-cloud system | No CMMC assessment of its own is required, but the services are assessed in the client’s scope | FAQ E-A3, 170.16(c)(3) |
| MSP does IT support, MSSP holds SPD, no CUI goes to either | Both are ESPs and are assessed in the client’s scope. Neither needs its own certification | FAQ E-A4 |
| MSP administers a cloud tenant subscribed or licensed to the client, even if the MSP resold it | The MSP is not a CSP | FAQ E-A5, Scoping Guide |
| MSP contracts with the CSP and modifies the basic service | The MSP may be a CSP and must meet FedRAMP or equivalency | FAQ E-A5 |
| Non-FedRAMP cloud holding encrypted CUI | Not allowed unless the provider meets FedRAMP Moderate or equivalency. Encryption does not remove the requirement | FAQ E-A2 |
| Staff augmentation, where the client provides all processes, technology and facilities | No CMMC assessment needed | Scoping Guide |
| Internal shared SOC or NOC in the same corporate group | Can still be an ESP, with the same requirements | Scoping Guide |
| MSP gets assessed voluntarily to shorten client audits | Allowed. Level and type must match or exceed the client’s contract requirement and cover in-scope assets | 170.19(c)(2)(ii), FAQ E-A3 |
What this means for MSPs
For a small client that would have needed a C3PAO under Phase 2, the suspension moves the near-term bill from $104,670 to $37,196 in DoD’s model, and that self-assessment model still assumes 88 ESP hours from someone like you, worth $22,905 at $260.28. It lowers paperwork pressure, not the underlying duty: the affirming official still attests every year that requirements are implemented, and DIBCAC retains the right to assess.
Three things are worth doing this quarter. Write the service description and customer responsibility matrix now, because 170.19(c)(2)(ii) requires both whenever you qualify as an ESP, and a client’s SSP has to refer to them. Map which of your tools hold SPD, since that one test decides whether you are in the client’s scope. Do not pitch a C3PAO engagement for your own firm as a requirement: the FAQ says it is optional, DoD published no price for it, and the program’s next shape is unknown. If you want it anyway, run the estimator with your own size to see DoD’s figure. DoD’s ESP line is paid work for a sector whose jobs, wages and establishments we track in our MSP industry statistics.
What you have to pass: 110 requirements, 88 points, 180 days
CMMC Level 2 is the 110 security requirements in NIST SP 800-171 Rev. 2, in 14 families, with 320 assessment objectives in DoD’s guide. Each is scored MET, NOT MET or not applicable (which counts as MET); the maximum is 110 and every NOT MET subtracts its value, which by our sum of the 170.24 point values can drive a score to -203. A conditional status needs at least 88 points (a ratio of 0.8), so at most 22 points can be open.
Must be MET at assessment (63) Can go on a POA&M (46) Only if encrypted but not FIPS-validated (1). Number is the point value; * is 3 or 5; S is the SSP.
Only 47 of the 110 can sit on a plan of action and milestones. Under 170.21(a)(2), nothing worth more than 1 point qualifies except FIPS-unvalidated encryption, and six requirements are barred by name: the SSP (3.12.4), external connections (3.1.20), public information control (3.1.22) and visitor escort, physical access logs and physical access management (3.10.3 to 3.10.5). That leaves 63 requirements that must be MET on assessment day.
| NIST SP 800-171 Rev. 2 family | Requirements | Objectives | 5 points | 3 points | 1 point | Can go on a POA&M |
|---|---|---|---|---|---|---|
| Access Control (AC) | 22 | 70 | 7 | 2 | 13 | 11 |
| Awareness and Training (AT) | 3 | 9 | 2 | 0 | 1 | 1 |
| Audit and Accountability (AU) | 9 | 29 | 2 | 1 | 6 | 6 |
| Configuration Management (CM) | 9 | 44 | 6 | 0 | 3 | 3 |
| Identification and Authentication (IA) | 11 | 25 | 3 | 0 | 7 | 7 |
| Incident Response (IR) | 3 | 14 | 2 | 0 | 1 | 1 |
| Maintenance (MA) | 6 | 10 | 2 | 2 | 2 | 2 |
| Media Protection (MP) | 9 | 15 | 2 | 3 | 4 | 4 |
| Personnel Security (PS) | 2 | 4 | 1 | 1 | 0 | 0 |
| Physical Protection (PE) | 6 | 16 | 2 | 0 | 4 | 1 |
| Risk Assessment (RA) | 3 | 9 | 1 | 1 | 1 | 1 |
| Security Assessment (CA) | 4 | 14 | 2 | 1 | 0 | 0 |
| System and Communications Protection (SC) | 16 | 41 | 5 | 1 | 9 | 10 |
| System and Information Integrity (SI) | 7 | 20 | 5 | 2 | 0 | 0 |
| All 14 families | 110 | 320 | 42 | 14 | 51 | 47 |
Requirements counted from NIST SP 800-171 Rev. 2. Objectives counted from DoD’s CMMC Level 2 Assessment Guide, version 2.13. Points from 32 CFR 170.24. Rows may not sum to the requirement count, because MFA (3.5.3) and FIPS encryption (3.13.11) score 3 or 5 and the SSP (3.12.4) has no point value.
- Closeout. NOT MET items on the POA&M must be fixed and closed out within 180 days of the Conditional CMMC Status Date. A C3PAO must perform the closeout for a certification assessment; a company performs its own for a self-assessment. DoD’s Level 2 tables carry $0 for this.
- One shot. FAQ C-A8: a closeout “can only be finalized” in eMASS “one time”. If anything is still NOT MET, the conditional status terminates and the company “will have to begin again with a new assessment”. The estimator’s rerun box prices that case.
- Re-evaluation. In a certification assessment, a NOT MET can be re-evaluated during the assessment and for 10 business days afterward if the findings report has not been delivered (170.17(c)(2)).
- Validity. Three years from the CMMC Status Date (Table 1 of the rule). The conditional date stays the status date after a successful closeout, so a closeout does not extend it.
- Affirmations. After each assessment, after any closeout, and annually. Table 1 of the rule says the assessment “will lapse upon failure to annually affirm”. DoD prices each at $1,459 (small) or $2,712 (other).
- Records. Assessment artifacts must be kept six years from the status date.
Frequently asked questions
How much does a CMMC Level 2 assessment cost?
DoD’s own estimate is $37,196 (small) to $48,827 (other) over three years for Level 2 (Self), and $104,670 to $117,768 for Level 2 (C3PAO). The C3PAO’s share is $31,234 to $52,056. Those are 2023 dollars and exclude implementing the 110 requirements. C3PAOs set their own prices: third-party claims run from about $30,000 to $150,000 for the fee.
Can you self assess CMMC Level 2?
Yes, when the solicitation designates Level 2 (Self). Since the July 13, 2026 suspension it is the only Level 2 designation Department of War program managers may use. The company self-assesses every three years against all 110 requirements, posts the score in SPRS and affirms annually. DoD’s estimate is $37,196 to $48,827 over three years, and its small-entity model assumes 88 hours of outside ESP help.
How long does it take to become CMMC Level 2 certified?
DoD publishes no end-to-end timeline for a C3PAO certification in the rule or its FAQ. Its cost model budgets a C3PAO team 120 hours (3 people) or 200 hours (5 people), which is 40 hours per assessor. A NOT MET item can be re-evaluated for 10 business days after the active assessment, and a plan of action must be closed within 180 days. Third-party claims range from six months to one year (Medium) to 12 to 18 months (IBSS); we could not verify them.
Is CMMC Level 2 still required?
Yes, as a self-assessment. On July 13, 2026 the Department of War suspended the move to Phase 2, so C3PAO and DIBCAC requirements may not be designated, but it said Phase 1 self-assessment requirements remain in place and DFARS 252.204-7012, which requires NIST SP 800-171, stays in effect. As of November 5, 2026 no replacement guidance is posted on the DoW CIO CMMC page.
Does an MSP need its own CMMC certification?
No. The DoW FAQ says an MSP is not required to have its own CMMC assessment, even when it stores CUI on a non-cloud system. Its services are instead assessed inside the client’s scope. An MSP may choose to get assessed to shorten client assessments, but the level and type must match or exceed the client’s contract requirement. DoD publishes no cost figure for that choice.
How much does CMMC Level 1 cost compared with Level 2?
DoD estimates Level 1 (Self) at $5,977 a year for a small entity and $4,042 a year for others. It covers 15 FAR requirements and allows no plan of action. Level 2 (Self) is $37,196 to $48,827 every three years and covers 110 NIST SP 800-171 Rev. 2 requirements.
Methodology
Sources and date. 32 CFR part 170 final rule (89 FR 83092) and its regulatory impact analysis; DFARS Case 2019-D041 final rule (90 FR 43560); eCFR part 170, current to November 3, 2026; Department of War release and two CIO memos of July 13, 2026; DoW CIO CMMC pages, FAQ revision 2.4, Level 2 Scoping Guide and Assessment Guide (v2.13); NIST SP 800-171 Rev. 2; SBA release 26-73. All retrieved November 5, 2026.
What we did. Tables 9 to 13 and 20 to 22 are images in the Federal Register, so we read them from the GovInfo PDF and transcribed them. Code then checks that hours times rate equals each printed line within $2, that lines sum to the published totals, and that each year’s Table 20 and 21 cost equals assessments and affirmations at the unit prices within 0.01%. We counted the 110 requirements and 320 objectives from the NIST and DoD documents and classified POA&M eligibility by applying 170.21 to the 170.24 point lists.
Estimator. Total = scopes x (cycles x one 3-year cycle + reruns x assessment plus first affirmation). Unit figures are DoD’s. Multiplying them for extra scopes, swapping team profiles and pricing failed attempts are our extensions, not DoD estimates. DoD says its numbers are averages, not prices. Figures stay in 2023 dollars; we did not inflate them.
Limits. Market figures are public statements, not quotes, and we did not test them. Summit 7’s guide returned 403 and was not read; Reddit was read only as a Google snippet. The Cyber AB marketplace was not scraped. The DPCAP class deviations page failed certificate verification on November 5, so we cannot confirm whether a class deviation implements the suspension. The task force’s report is not posted on the DoW CIO’s CMMC pages as of November 5, 2026, and a later release could supersede the C3PAO figures.
Not a quote, not legal advice. This is an analysis of public regulatory documents. Get written C3PAO quotes for a defined scope, and check requirements with your contracting officer or counsel.
Cite as:The Uptime Report. "CMMC Level 2 Assessment Cost: DoD Puts the C3PAO Fee at $31,234 to $52,056, and the Third-Party Mandate Is Suspended." November 2026. https://theuptimereport.com/cmmc-level-2-assessment-cost/
References
- Federal Register, Cybersecurity Maturity Model Certification (CMMC) Program, 89 FR 83092, October 15, 2024. Accessed November 2026.
- GovInfo PDF of the same rule (Tables 9 to 13 at pages 83178 to 83180, Tables 20 to 22 at pages 83185 to 83187). Accessed November 2026.
- Federal Register, DFARS: Assessing Contractor Implementation of Cybersecurity Requirements, 90 FR 43560, September 10, 2025. Accessed November 2026.
- eCFR, 32 CFR Part 170 (sections 170.3, 170.4, 170.16, 170.17, 170.19, 170.20 to 170.24), current to November 3, 2026. Accessed November 2026.
- U.S. Department of War, “Forging the Arsenal of Freedom: Department of War Suspends CMMC Phase II Requirements,” July 13, 2026. Accessed November 2026.
- DoW CIO memo, “Removing Barriers to Defense Industrial Base Expansion,” July 13, 2026. Accessed November 2026.
- DoW CIO, Implementing Suspension of CMMC Phase II, with Attachment 1, July 13, 2026. Accessed November 2026.
- DoW CIO, Cybersecurity Maturity Model Certification page. Accessed November 5, 2026.
- DoW CIO, CMMC Frequently Asked Questions (revision history through 2.4, July 13, 2026). Accessed November 2026.
- DoD CIO, CMMC Scoping Guide Level 2, version 2.13. Accessed November 2026.
- DoD CIO, CMMC Assessment Guide Level 2, version 2.13. Accessed November 2026.
- NIST SP 800-171 Rev. 2. Accessed November 2026.
- U.S. Small Business Administration, news release 26-73, July 13, 2026. Accessed November 2026.
- Covington, Inside Government Contracts, “CMMC Reform Task Force Updates September 2026,” September 21, 2026 (secondary, for report status only). Accessed November 2026.
- The Cyber AB, Terms of Use (bots and automated data gathering prohibited; marketplace not scraped). Read October 2026.
- cmmc.com, September 22, 2025 (third-party claim); Paramify (third-party claim); Workstreet, January 23, 2026 (third-party claim); PreVeil, August 21, 2026 (third-party claim); Secureframe (third-party claim); Vanta (third-party claim); IBSS on LinkedIn, September 9, 2026 (third-party claim); Tyson Martin on Medium, December 6, 2025 (third-party claim). Accessed November 2026.
Research library
More original data reports from The Uptime Report. Every report includes its methodology and a free CSV download. Browse all research
Threats and breaches
- AT&T Data Breach Settlement Payout Date
AT&T payout status, tiers, incident history - Microsoft Data Breach History
Microsoft incidents by type, 2020 to 2026 - IC3 Report 2025
IC3 losses, crime types, states per capita - AI Incidents Statistics 2026
AI incidents by year, harm type, company - Cyber Attacks 2026
Every 2026 cyber attack, primary-sourced - WordPress Vulnerabilities
WordPress plugin, theme and core CVEs - Hypervisor Vulnerabilities
Hypervisor CVEs vs exploitation - DMARC Adoption Statistics 2026
DMARC enforcement, 15,000 domains - RMM Vulnerabilities and Remote Access Flaws
RMM and remote access flaws in KEV - Identity Theft Statistics 2026
ID theft per 100K by state and type - Scam Statistics 2026
FTC fraud losses by channel and age - VPN Vulnerabilities by Vendor
VPN gateway KEV and CVEs by vendor - MFA Statistics 2026
MFA methods across 2,571 services - Password Statistics 2026
12,674 passwords tested against HIBP - Ransomware Groups 2026
Most active ransomware groups, ranked - Ransomware Statistics 2026
Leak-site victims by month since 2021 - Malicious npm Packages
Malicious npm packages, day by day - Cybersecurity Statistics 2026
70 sourced stats, every number traced - Zero-Day Statistics
Every tracked zero-day since 2014 - Phishing Statistics 2026
Four phishing measures, one evidence board - Patch Tuesday Statistics 2026
Every Microsoft CVE since 2021 - Disaster Declarations by State
FEMA data for continuity planning - Data Breach Statistics 2026
980 breaches in Have I Been Pwned - Ransomware Initial Access Vectors
CISA advisories coded by entry technique - CVE Statistics 2026
Vulnerabilities published per year, NIST NVD - How Long Do Companies Take to Report a Data Breach?
1,675 Washington notices - Known Exploited Vulnerabilities
The CISA KEV catalog analyzed - Healthcare Data Breach Report 2026
HHS OCR breach portal scorecard - Ransomware Reported to the FBI
Five-year IC3 trend - ConnectWise ScreenConnect Vulnerabilities
ScreenConnect CVEs dated, with version lookup - SonicWall Vulnerabilities 2026
SonicWall CVEs by product line and KEV year - Dental Practice Data Breaches 2026
Every 2026 dental breach on the HHS portal - Apple Zero Days 2026 List
Every Apple-flagged CVE, with KEV dates - Android Zero Days 2026
Android flags by layer, OEM patch lag - Auto Dealership Data Breach 2026 Tracker
Dealer and vendor breaches by state filing - Law Firm Data Breaches 2026
Every law firm AG notice, sized and dated - Accounting Firm Data Breach 2026
CPA breach notices against the tax calendar - Bank DMARC Adoption 2026
DMARC at 4,118 US banks, by size - MSP Email Security
MSP DMARC and SPF, 1,430 domains - Credit Union Cybersecurity Statistics 2026
55% of credit unions skip DMARC - Citrix NetScaler Vulnerabilities 2026
48 NetScaler CVEs, 6 exploited, build checker - Fortinet Vulnerabilities 2026
Every 2026 Fortinet CVE, by product - Okta Vulnerabilities
Okta CVEs and incidents, two ledgers - Veeam Vulnerabilities
Veeam CVEs, fixed builds, KEV flags - Atlassian Confluence Vulnerabilities
Confluence CVEs, KEV and LTS fixes - SolarWinds Vulnerabilities
338 SolarWinds CVEs, 11 exploited in KEV - SAP NetWeaver Vulnerabilities
Every SAP NetWeaver CVE, by Patch Day - N-able Vulnerabilities
N-able CVEs, fixed builds and KEV flags
Infrastructure and uptime
- Data Centers Using Nuclear Power
Every US nuclear deal, by NRC stage - Claude Outage History
934 Claude incidents by model and hour - AMD vs Nvidia Market Share Over Time
AMD vs Nvidia share: Steam and SEC filings - iPhone Market Share by Country 2026
iPhone share in every country - Android Market Share by Version 2026
Android versions and patch status - OpenAI Outage History
1,051 OpenAI incidents, causes coded - Data Center Construction Spending 2026
Data center build spending, Census monthly - Microsoft End of Support 2026
Every 2026 Microsoft support cutoff - Fiber Internet Availability by State 2026
Fiber by state, build pace, top providers - 5G Coverage Map 2026
5G by state and carrier, FCC data - Cell Phone Outage History
FCC outages, DIRS cell sites, 911 fines - Mac Market Share 2026
Mac desktop share by country and version - Browser Market Share 2026
Browser share since 2009, by platform - Microsoft 365 Market Share 2026
Who runs email: Microsoft vs Google - CrowdStrike Outage
July 19, 2024 outage, minute by minute - Data Center Electricity Prices 2026
Power prices vs data center load, by state - Average Internet Bill 2026
Home internet prices by speed and state - Search Engine Market Share 2026
Search share since 2009, by country - ChatGPT Market Share 2026
AI chatbot referral share, every tracker - Google Cloud Outage History
Google Cloud incidents by product, 2013 on - Azure Outage History
Every Azure PIR, coded by root cause - Data Center Water Usage 2026
Water by site, company and drought - AI Energy Consumption 2026
Big Tech electricity vs US demand - SSD Prices 2026
NAND price cycle from makers’ filings - RAM Prices 2026
DRAM prices from producers’ filings - Domain Name Statistics 2026
Domains by TLD, renewals, registrars - Linux Market Share 2026
Linux desktop share, every headline traced - GitHub Outages
GitHub incidents by month since 2020 - Cloudflare Outage History
Every Cloudflare outage post-mortem - Starlink Statistics 2026
Satellites, subscribers, coverage, outages - Internet Access Statistics 2026
Home internet gaps by state and group - SQL Server End of Life
SQL Server support countdown + CVEs - Windows 11 Market Share 2026
Windows 10 vs 11 share by country - Cloud Computing Statistics 2026
Hyperscaler revenue and capex, SEC data - AWS Outage History
Every AWS Post-Event Summary since 2011 - Data Centers by State 2026
Sites, jobs, power for every state - Data Center Statistics 2026
Data center power, spending, jobs - 99.9% Uptime
Uptime calculator and 35 real SLAs - Power Outage Statistics by State
Outage hours by state, EIA data - Cost of Downtime
Revenue per hour for 3,001 public companies - Windows Server End of Life
Support dates and CVEs per server version - SQL Server 2016 ESU Cost
ESU cost calculator, every formula - Slack Outage History
1,459 Slack entries, SLA history, ledger - Google Workspace vs Microsoft 365 in US Schools
Google vs Microsoft in 10,591 districts - Block GPTBot
AI crawler blocks across top 10k sites - security.txt Adoption 2026
Who publishes a valid security.txt - Government Email Security 2026
.gov DMARC: local 40% vs federal 88% - Government Website Security 2026
.gov web security scored by state - vSphere 8 End of Support
vSphere 8 dates, exploited flaws by version - Office 2019 End of Life
Office 2019 EOL: who still gets patches - Zoom Outage History
Every Zoom incident since 2015 - Office 2021 End of Life
177 flaws fixed a month after support ended - Exchange Server 2019 End of Life
Exchange 2019 EOL, ESU builds and CVEs - FortiOS 7.0 End of Life
FortiOS 7.0 dates, builds and unfixed flaws
Regulation and disclosure
- Are Ransomware Payments Illegal? Law by Jurisdiction
Who may pay a ransom, by jurisdiction - HIPAA Security Rule Changes 2026
Security Rule status: current vs proposed - FTC Safeguards Rule Breach Notification
500-consumer, 30-day FTC breach duty - Data Center Moratorium by State 2026
Moratoria and bans in every state - State Privacy Laws 2026
23 state privacy laws, compared - State AI Laws 2026
131 state AI laws, dates and penalties - FedRAMP Statistics 2026
FedRAMP authorizations, GSA data - Item 1C Cybersecurity Disclosures
What 600 10-Ks say in Item 1C - CMMC Certification Statistics 2026
CMMC demand vs assessor capacity - Data Brokers List 2026
728 brokers across three state registries - SEC Cybersecurity Incident Disclosures
Every 8-K Item 1.05 filing - HIPAA Enforcement Tracker
Every OCR penalty and settlement - Safe Harbor Cybersecurity Laws by State
10 states, 11 laws, framework grid
Workforce and pay
- Intel Layoff Tracker
Every Intel WARN notice, by site and date - Amazon Layoffs by State
Amazon WARN notices, state by state - Oracle Layoffs by State
Oracle WARN notices and restructuring cost - Cloud Architect vs Cloud Engineer Salary
Architect vs engineer pay, H-1B filings - Entry Level DevOps Engineer Salary
Entry level DevOps pay, H-1B filings - Microsoft Layoff History Timeline
Every round dated, 2009 to 2026 - Google Layoffs by Year
Notices, headcount, severance by year - AI Engineer vs ML Engineer Salary
AI vs ML engineer pay, from H-1B filings - Data Engineer Salary by Experience
Data engineer pay by DOL wage level - Most Popular Programming Languages 2026
Language ranks by country, GitHub data - Computer Science Graduates Per Year
CS degrees per year, IPEDS 2011 to 2024 - Data Scientist Salary 2026
Data scientist pay ladder and metros, BLS - Web Developer Salary 2026
Web dev vs software pay by state, BLS - AI at Work Statistics 2026
Worker AI use: ever, weekly, daily, by job - Network Engineer Salary 2026
Network engineer vs admin pay, BLS - IT Manager Salary 2026
IT manager pay by industry, BLS OEWS - Software Engineer Salary 2026
Developer pay by metro, BLS OEWS - H-1B Statistics 2026
H-1B lottery, employers, and wages - AI Layoffs 2026
AI-blamed job cuts, sourced to filings - Help Desk Salary 2026
Help desk hourly pay, BLS OEWS - Cybersecurity Salary 2026
Security pay percentiles, BLS OEWS - Women in Tech Statistics 2026
Women’s share of tech jobs since 2011 - IT Unemployment Rate 2026
Tech vs national jobless rate, monthly - Tech Job Postings 2026
Tech postings vs 2020, by role and country - Tech Layoffs 2026
Tech layoffs from state WARN notices - Remote Work Statistics 2026
Telework by job, industry, and state - Highest Paying Cities for IT Jobs 2026
Metro pay by role, BLS OEWS - The Tech Job Market in 2026
Openings, quits, hires, layoffs - IT Salaries by State 2026
Pay matrix for four IT roles - IT and Cybersecurity Jobs Outlook 2026
BLS employment projections - Salesforce Layoffs by State
Salesforce WARN notices, state by state - Dell Layoffs by Year
Headcount, severance, notices by year - IBM Layoffs by Year
IBM workforce charges against headcount - Meta Layoffs by Year
Meta rounds, sites and headcount by year - IT Director vs IT Manager Salary
IT director vs manager pay, H-1B filings - Penetration Tester Salary Entry Level
Entry level pen test pay, H-1B filings - Site Reliability Engineer vs DevOps Salary
SRE vs DevOps pay, H-1B filings - Solutions Architect vs Software Engineer Salary
Architect vs engineer pay, Level I to IV - Data Engineer vs Data Analyst Salary
Data engineer vs analyst pay, H-1B ledger - Network Engineer vs System Administrator Salary
Network engineer vs sysadmin pay by state - Security Analyst vs Security Engineer Salary
Analyst vs engineer pay, step by step - Cloud Engineer vs DevOps Engineer Salary
Cloud vs DevOps pay by metro, H-1B - Cisco Layoffs by Year
Cisco cuts by year: charges vs staff - Database Administrator vs Data Engineer Salary
DBA vs data engineer pay, reconciled - Penetration Tester vs Security Engineer Salary
Pen tester vs engineer pay: near tie - Help Desk vs Desktop Support Salary
Help desk vs desktop pay, one BLS code
MSP market and spending
- AI Capex 2026
Big Tech capex vs cash flow, SEC data - Cybersecurity Budget 2027
Federal and CISA cyber budgets, benchmarks - Microsoft 365 Price Increase 2026
Every M365 price change, vs inflation - Computer Prices 2026
Computer price indexes and HS 8471 imports - MSP Market Size 2026
Managed services market, built from Census - Small Business AI Adoption 2026
AI use by firm size, sector, state, Census - Cyber Insurance Statistics
Cyber insurance market, NAIC 2015-2024 - IT Spending by Industry
IT investment by industry, BEA - IT Services Industry Growth 2026
Census revenue by service industry - IT Hourly Rates 2026
Hourly IT labor rates, GSA contracts - VoIP Statistics 2026
Business VoIP vs landlines, FCC - MSP Industry Statistics 2026
Jobs, wages, and firms, BLS QCEW - Federal IT Spending 2026
IT services contracts, USAspending - IT Services Firms by State
Census business patterns atlas - How Much Do MSPs Charge Per User?
Published MSP prices, 1,310 websites - VMware Price Increase Broadcom Timeline
Broadcom VMware changes and revenue, dated - Adobe Price Increase History
Every Adobe price change, vs inflation - Atlassian Price Increase History, 2019 to 2026
Every Atlassian price hike, dated - Zoom Price Increase 2026
Every Zoom price change since 2013
Leave a Reply