CMMCComplianceCostBreakdownforTier-2Contractors

Every estimate of CMMC cost starts with the same two problems. First, vendors anchor to the technology line item because it is easy to price. Second, the DoD cost estimates in the rule-making record assume a baseline of existing NIST 800-171 maturity that almost no tier-2 contractor actually has. The result is a published average that is often half of what the work truly costs.

This breakdown reflects what a tier-2 contractor with 50-250 seats, a handful of CUI-handling engineers, and no prior formal compliance program should actually budget to reach CMMC Level 2 with a C3PAO-ready posture. All figures are in USD.

Year one: the lift to assessment readiness

Gap assessment and scoping: $18,000 - $45,000

The non-negotiable starting point. A qualified assessor maps every business process that touches CUI, inventories the assets in each of the five CMMC scoping categories, and produces a gap analysis against the 110 controls in NIST 800-171. The range reflects depth: a superficial checklist is cheaper and almost always insufficient; a defensible scoping exercise with CUI data flow diagrams and SPA/CRMA classifications runs toward the upper end.

Where the estimate goes wrong: contractors skip this step or internalize it to save money, then discover during the C3PAO audit that half the assets they excluded from scope are actually in scope. Rework cost: 2-3x the original gap assessment.

Enclave architecture and segmentation: $35,000 - $120,000

The single biggest architectural decision. Options, in ascending cost:

• Logical enclave on existing infrastructure: network segmentation via VLANs and firewall policy, dedicated VDI or jump host for CUI access, and a separate M365 GCC High tenant for CUI email and file storage. Typical build: $35-60k plus GCC High license delta.
• Dedicated physical enclave: isolated endpoints, separate identity plane, air-gapped or tightly controlled data diode for ingress/egress. Typical build: $75-120k, appropriate for higher sensitivity or when enterprise IT cannot be trusted to maintain segmentation discipline.

The hidden cost: every existing SaaS integration that previously "just worked" now needs re-evaluation. Ticketing, e-signature, file share, CI/CD, monitoring - each either earns FedRAMP equivalence or gets a replacement. Plan for 4-8 tool swaps.

Tooling uplift: $40,000 - $90,000 year one

Typical uplift for a shop running commercial-grade tooling:

• EDR/MDR on GCC High or FedRAMP Moderate tier: $35-60/endpoint/year delta vs commercial
• SIEM with CUI-compatible retention and access controls: $25-50k/year at this size
• FIPS-validated VPN or ZTNA: $15-30k/year
• Vulnerability management platform: $12-25k/year
• Privileged access management: $20-40k/year
• Security awareness training platform tuned to DoD insider threat content: $8-15k/year

Where the estimate goes wrong: vendors bundle "CMMC-ready" packages without specifying which of the 110 controls they actually address. A $40k bundle that covers 15 controls leaves 95 still requiring evidence.

Labor: policy, procedure, and SSP: $60,000 - $150,000

Someone has to write the System Security Plan, author 14 control-family policies, document every procedure, build the evidence library, train staff, and run the internal audit dry runs. This is rarely absorbable by existing IT staff - SSP documentation alone is 200-400 pages for a tier-2 enterprise.

Approaches, in ascending cost to the contractor:

• In-house FTE: a dedicated compliance lead at $110-140k fully loaded. Best long-term answer but slow to onboard.
• vCISO engagement: $8-15k/month for 12-18 months. Fastest path to a defensible SSP.
• Consulting firm with DIB specialization: $80-150k fixed fee for readiness program.

C3PAO assessment: $40,000 - $110,000

The formal Level 2 assessment. Price varies with scope size, geographic spread, and assessor bench. Tier-2 contractors with a well-defined enclave typically land in the $50-75k range. Contractors who enter the audit with poor scoping, no SSP, or unresolved high-severity gaps end above $100k because the assessor burns time on clarification and re-sampling.

Add pre-assessment readiness review (often by the same or a sister firm): $20-40k. This is almost always worth it.

Contingency: 15-20% of the total

Something always costs more than planned. Usually it is the realization during the dry-run audit that one control family is three months short of evidence and a compressed remediation sprint follows.

Year-one total: $235,000 - $705,000

The low end represents a disciplined tier-2 contractor with existing baseline maturity, strong enclave scoping, and internal change control already in place. The high end represents a contractor starting near zero and pursuing a rigorous audit posture.

Recurring annual cost

CMMC is not a project; it is an operational posture. Ongoing annual costs for a maintained Level 2 environment:

• Tooling license renewals: $70,000 - $170,000 (depending on scope)
• Compliance staff (continuous monitoring, evidence collection): $80,000 - $180,000
• Annual penetration test: $15,000 - $35,000
• Insider threat program and training: $5,000 - $15,000
• Internal audit and POA&M maintenance: $15,000 - $30,000
• Triennial C3PAO re-assessment (amortized): $15,000 - $40,000/year

Annual recurring total: $200,000 - $470,000.

Where contractors waste money

• Over-scoping: running the entire corporate network through a CMMC assessment instead of building an enclave. Frequently 3x the necessary cost.
• Tool sprawl: buying four niche "CMMC tools" that each solve one control instead of consolidating on a platform that addresses a control family.
• Delayed start: compressed timelines force emergency consulting rates (2x standard) and higher assessor premiums.
• Skipping readiness review: the $25k spent on a readiness assessment avoids $100k+ of failed-audit remediation.
• Outsourcing the SSP to a single consultant with no internal knowledge transfer: the document becomes unmaintainable the moment the consultant rolls off, and the next contractor update or scope change forces a second authoring engagement.
• Under-budgeting for evidence collection: the technical control exists, but the log exports, screenshots, and procedural artifacts that prove it exists for an assessor were never assembled. Evidence collection during a live audit is 3-5x more expensive than during steady-state.

Sizing sensitivities

The ranges above scale with headcount, but not linearly. Two contractors with identical 150-seat environments can produce cost deltas of 2x based on:

• Geographic footprint: a single facility is meaningfully cheaper to scope and assess than a three-location enterprise with remote workers
• CUI concentration: a shop where CUI touches every engineer is more expensive than one where CUI is bounded to a small contracts-and-engineering enclave
• Prior maturity: a contractor with existing SOC 2 or ISO 27001 will reuse substantial policy, procedure, and evidence material
• Internal discipline: firms with strong existing change management, configuration baselining, and IT governance move through CMMC faster and cheaper

The decision frame

Before writing any checks, determine whether CMMC cost is justified by the revenue at stake. If DIB contracts represent less than 15% of revenue and the remediation pathway exceeds 24 months of that revenue contribution, the right answer may be to exit that portion of the business or reposition as a tier-3 supplier flowing work through a compliant prime. This is a board-level conversation, not an IT conversation.

For contractors committed to the DIB path, starting early and building an intentional enclave are the two highest-leverage cost controls. Techvera runs CMMC readiness programs for tier-2 DIB contractors across our service regions. See our government and defense practice or book a consultation to walk through your revenue exposure and cost model.