Why Do Some Companies Underestimate the Documentation Burden of CMMC Requirements?

Many defense contractors assume that meeting CMMC requirements is as simple as having a few cybersecurity policies in place. The reality is much more demanding. CMMC compliance requirements require extensive documentation, continuous updates, and alignment with actual security practices. Companies often don’t realize the complexity until they are deep into the assessment process, leading to unexpected challenges and delays. 

Misjudging the Complexity of Required Documentation 

Companies often assume that passing a CMMC level 1 requirements assessment is just a matter of presenting existing security policies. However, documentation requirements go far beyond policy statements. Organizations must provide clear, structured records showing how security controls are implemented, managed, and continuously improved. 

A CMMC level 2 requirements assessment, in particular, demands detailed evidence of cybersecurity practices, from access control to system monitoring. Simply having the right security tools in place isn’t enough—organizations must prove they follow documented procedures consistently. Companies that treat documentation as an afterthought risk failing their assessment, even if they have strong security measures in practice. 

Overlooking the Need for Detailed Process Descriptions 

Security policies alone won’t meet CMMC compliance requirements. Companies must also document step-by-step procedures outlining how security measures are enforced. This includes defining responsibilities, explaining how security controls are tested, and detailing remediation steps when issues arise. Without this level of detail, assessors may struggle to verify compliance. 

Another common mistake is inconsistency in documentation. Even if a company follows best security practices, poorly written or vague documentation can create confusion during an audit. CMMC level 2 requirements expect organizations to document processes in a way that anyone—inside or outside the company—can understand and follow. If key details are missing, companies may face assessment delays, failures, or costly remediation efforts. 

Assuming Existing Policies Suffice Without Updates 

Some organizations rely on outdated security policies, assuming they still meet CMMC requirements. However, cybersecurity threats and regulatory standards evolve, and policies that were sufficient a few years ago may no longer align with CMMC compliance requirements. Failing to regularly update documentation creates gaps that auditors will flag during an assessment. 

The CMMC level 1 requirements assessment ensures organizations maintain accurate and current policies, not just old documents that no longer reflect reality. To stay compliant, businesses must continuously review and update their security documentation, ensuring policies align with operational changes and emerging cybersecurity risks. Without these updates, companies risk non-compliance and potential contract losses. 

Neglecting Regular Reviews and Updates of Documentation 

Compliance documentation is not a one-time task. Many organizations overlook the need for routine reviews, leading to last-minute updates before a CMMC level 2 requirements assessment. This rushed approach increases the likelihood of errors, missing details, and inconsistencies that could result in a failed assessment. 

Regular documentation reviews help ensure that security policies, procedures, and system controls remain aligned with evolving threats and operational practices. Companies that integrate routine compliance updates into their cybersecurity strategy are better prepared for audits and reduce the risk of unexpected failures. Those that neglect this process may find themselves scrambling to fix security gaps when an assessment is imminent. 

Underestimating the Time Commitment for Proper Documentation 

One of the most significant miscalculations companies make is assuming that security documentation can be completed quickly. Writing, reviewing, and maintaining records that meet CMMC requirements requires significant time and resources. Many businesses don’t allocate enough personnel or effort to this task, resulting in incomplete or inadequate documentation. 

The CMMC compliance requirements assessment process requires documentation that is thorough, well-organized, and verifiable. Proper documentation involves collaboration between IT, compliance teams, and leadership to ensure accuracy. Companies that underestimate the time and effort required often struggle to complete documentation before their assessment, leading to unnecessary stress and costly delays. 

Failing to Align Documentation with Actual Practices 

A major issue during a CMMC level 2 requirements assessment is when documentation does not reflect real-world security practices. Some companies create polished policies that look strong on paper but fail to align with daily operations. Auditors will quickly identify discrepancies between documented procedures and how security is actually managed. 

To pass a CMMC compliance requirements assessment, organizations must ensure that their documentation accurately represents their cybersecurity practices. This means mapping security controls to documented policies, verifying that employees follow the stated procedures, and demonstrating leadership enforcement of compliance. When documentation aligns with reality, companies not only improve their chances of certification but also strengthen their overall security posture.