Even before diving into technical details, a C3PAO can pick up on problems fast—sometimes in the first few minutes. It’s not about being picky; it’s about spotting patterns that show whether a company is truly ready. These assessments aren’t meant to trip you up, but they do show how well your team really understands cybersecurity.
Documentation Lacking Clarity and Uniformity Across Security Controls
A big red flag C3PAOs catch right away? Sloppy or inconsistent documentation. When the policies and procedures don’t match across different parts of the organization, it shows that security isn’t being applied the same way everywhere. CMMC compliance requirements expect clear, repeatable processes—especially at CMMC Level 2 where documentation needs to match the control practices. A messy paper trail creates doubt that your team follows the same standards consistently.
Some businesses think just having the documents is enough, but if one policy uses different terms than another or misses steps others mention, your assessor will notice. A trained C3PAOs pots those mismatches quickly. They’re looking for evidence that the entire organization—not just IT—knows and uses the same playbook. That consistency is what proves maturity and readiness during a CMMC assessment.
Absence of Comprehensive Inventory for Critical Digital Assets
One thing your C3PAO always looks for early on is your asset inventory—basically, a list of everything digital that matters. This includes laptops, servers, mobile devices, software tools, cloud services, and even external storage drives. If this list is missing, outdated, or incomplete, it’s a big problem. Why? Because without knowing what you have, you can’t protect it. Meeting CMMC Level 1 requirements starts with knowing your assets. Level 2 takes it even further.
A good inventory doesn’t just include names and serial numbers. It should say what each asset does, who uses it, and whether it touches Controlled Unclassified Information (CUI). A C3PAO will ask, “If something goes wrong, do you know exactly what’s affected?” If the answer’s no—or even maybe—it signals gaps in your security foundation. This is one of the easier things to fix, but only if you know it’s broken in the first place.
Systems and Software Left Vulnerable Due to Neglected Patch Management
When systems aren’t patched regularly, your whole environment becomes a target. C3PAOs know this and will immediately check whether software updates and security patches are applied on time. If they find unpatched software, outdated firmware, or unsupported tools still in use, that’s a serious hit. Even at CMMC Level 1, you’re expected to keep tech updated. At Level 2, patch management becomes even more important.
Patch management isn’t just about clicking “update.” It’s a regular, scheduled process that includes testing patches, verifying installations, and tracking what’s been fixed. During a CMMC assessment, assessors may ask for proof—like logs or screenshots—that patches are installed within a reasonable time frame. If your process is just “whenever we remember,” they’ll know right away. Strong patching habits show that you’re actively managing risks instead of waiting for something to break.
Inadequate Enforcement of User Privileges and Permissions
Giving employees more access than they need is a security risk. C3PAOs pay close attention to user permissions—who can log into what, who can change settings, and who can see sensitive data. If users have admin rights when they don’t need them, or if there’s no review process for changing access, your assessor will flag it. CMMC compliance requirements call for strict access control, especially at Level 2.
This doesn’t just mean locking down everything. It means having a clear plan for how access is granted, changed, and removed. For example, when someone switches roles or leaves the company, does their access change right away? A good C3PAO can tell if access controls are just set once and forgotten—or if they’re part of a living, working system. If they’re sloppy, your security posture is weaker than you think.
Logs That Are Either Missing, Incomplete, or Insufficient for Accurate Security Monitoring
Logs are like a security camera for your network. They tell you what happened, when, and who was involved. But too often, organizations either don’t keep logs long enough or don’t collect the right data. C3PAOs notice this fast. When logs are missing—or worse, exist but aren’t checked regularly—it tells the assessor that threats might go undetected for too long. That’s a deal-breaker for CMMC Level 2 requirements.
Monitoring logs doesn’t mean watching every line in real time. It means knowing what to look for, where to look, and how to spot something strange. Your CMMC assessment will likely include questions about where your logs are stored, how long you keep them, and who reviews them. If no one can answer those questions confidently, that sends a clear signal to the assessor that the monitoring process is weak or missing entirely.
Underdeveloped Incident Response Plans Leading to Delayed or Ineffective Cybersecurity Reactions
The C3PAO doesn’t just want to know you have an incident response plan—they want to see how well it works. If the plan is vague, outdated, or never tested, that becomes obvious quickly. CMMC Level 2 requires not just having a plan, but also practicing it. When cyber incidents happen, time matters. A plan on paper won’t help if nobody knows their role during a real emergency.
Your incident response plan should cover things like who’s in charge, how incidents are reported, and what steps to take to contain and recover. A strong plan includes contact lists, templates for alerts, and a record of past drills. During your assessment, the C3PAO may ask how your team handled a past issue or whether you’ve run tabletop exercises. If the answer is silence or confusion, that speaks louder than the plan itself.
