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In the lead-up to the final rule publication in October 2025, most contractors assumed that CMMC compliance would be their biggest concern.

In fact, the most significant issue is the shortage of accredited assessors.

CMMC Level 2 and above requires evaluation by a Cyber AB Accredited Assessor, also known as a CMMC third-party assessor organization (C3PAO). It’s estimated that there are hundreds of thousands of organizations requiring certification, with a limited number of qualified assessors available.

It’s estimated that fewer than 600 qualified assessors exist globally. To become certified as a CMMC assessor, each must pass a Tier 3 federal background check, a process that typically takes up to eight months.

This shortfall could well be a bigger threat to national security than non-compliance itself. Without certification, defense contractors will be unable to renew or accept contracts subject to DFARS requirements, and many projects may stall as a result.

Delayed certification could well curtail access to innovation and research and will undoubtedly adversely impact organizations that depend on the defense industrial base (DIB) for their continuity.

Bottom line, the crisis is not just an administrative challenge; it’s a massive supply chain risk with dire implications on national security.

Assessor Shortages Impact Sectors Beyond Defense

Though Essendis views CUI primarily through a defense lens, sensitive CUI does not solely reside in that realm. Law enforcement, crimes against children, intellectual property, pharmaceuticals, healthcare, and aeronautics are among the sectors with CUI concerns.

Though some of these industries may not ordinarily align with defense agendas, they have adopted CUI protections aligned with federal standards, as have NATO, Five Eyes, and other international frameworks of this kind.

In light of this movement, it is expected that many sectors will adopt similar strategies and move towards standardizing the cybersecurity model to meet compliance mandates.

With the looming backlog prioritizing defense, it’s unclear what compliance and certification will look like for these markets.

Unpacking The Impact of Assessor Shortages

Recent media coverage has highlighted assessor shortages as a significant bottleneck. However, there has been little public discussion about how long this backlog may last or what interim mitigation measures look like for subcontractors or smaller firms.

Phased assessments are now rolling out, with many organizations required to self-certify in lieu of an official evaluation. It is assumed that priority will be given to organizations with critical security mandates, but again, there is no clarity on how that will shake up.

More assessors are needed, obviously, but there does not seem to be any indication of how the shortfall will be addressed in the near term. There is currently no widespread modeling or scenario analysis of how assessor shortages might slow down the transition or impact small contractors’ ability to bid on new contracts.

What does seem clear is that there will be contract delays, lost opportunities, and increased risk to the DoD supply chain.

In any case, CMMC readiness is essential. Even if self-certification is an option, there will be a reckoning down the road. Organizations that are unprepared for their assessment when a slot opens may be passed over, not because they are unworthy, but simply because of assessor availability and the need to focus efforts on organizations prepared to meet the challenge.

Connect with an expert today to book your CMMC 2.0 readiness assessment.

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