CMMC & Penetration Testing 2025: What DoD Contractors Must Know

• CMMC Cybersecurity Maturity Model Certification is a DoD cybersecurity framework with 3 levels, required for defense contractors handling sensitive data.
• Does CMMC require penetration testing? Not explicitly at Level 1-2, but Level 3 does include a pentesting requirement to counter advanced threats. Even for lower levels, CMMC’s practices vulnerability management, risk assessments strongly encourage proactive testing.
• Penetration testing helps DoD contractors find and fix vulnerabilities in their networks, apps, and cloud before adversaries do. It validates that security controls like those in NIST SP 800 171 actually work in practice.
• Integrating regular pentests into your CMMC compliance program bridges the gap between paper compliance and real world security, reducing the risk of breaches and strengthening your case in CMMC audits.

What’s the deal with CMMC and penetration testing? If you’re a DoD contractor in 2025, you know CMMC 2.0 compliance is now essential for winning contracts. CMMC sets the baseline for protecting sensitive data like CUI on your systems.

But does CMMC explicitly mandate penetration testing as part of that? The short answer: not at Level 1 or 2, but it does at Level 3 and regardless of level, pentesting is one of the smartest moves you can make.

Why? Because checking your cyber defenses before a real attacker does just makes sense. Think of it this way: CMMC helps ensure you’ve locked all the doors and windows; a penetration test is like hiring a pro to rattle those locks and find any you missed.

Why this matters now: The defense industrial base is under attack literally. The DoD reports increasingly frequent, complex cyberattacks on contractors, often by state sponsored hackers.

If you handle controlled unclassified info for DoD, a breach at your company can become a national security risk. That’s why CMMC was created to stop relying on trust and start verifying that contractors have solid security.

Penetration testing aligns perfectly with that mission by providing proof that your security controls hold up under real world exploits. So in this guide, we’ll break down what CMMC requires, how pentesting fits in, and why it’s a must have for compliance even when it’s not explicitly written on the tin.

What Is CMMC?

CMMC stands for Cybersecurity Maturity Model Certification. It’s a unified security standard for DoD contractors designed to protect sensitive data like Federal Contract Information FCI and Controlled Unclassified Information CUI on non government systems.

In plain terms, if your company does work with the U.S. Department of Defense, CMMC is the set of cybersecurity requirements you need to meet and prove you meet. Prior to CMMC, contractors mostly just self attested their security e.g. Sure, we follow NIST 800 171. Now, with CMMC, the DoD is moving from trust to verify. You must get certified at the required CMMC level to be eligible for contracts.

Who needs CMMC? Potentially over 200,000 organizations in the defense supply chain from large primes to small subcontractors. If you handle DoD information FCI or CUI as part of a contract, you’ll need a CMMC certification at the level specified in the contract.

This includes manufacturers, software vendors, consultants, anyone down the supply chain. The only exceptions might be companies that only sell commercially available off the shelf products with no DoD data exchange.

CMMC 2.0 Levels: The latest CMMC 2.0 model has 3 levels of maturity down from 5 in version 1.0 to align with the sensitivity of information you handle:

• Level 1 Foundational
  • Basic cyber hygiene for companies handling FCI only no CUI. It has 17 simple practices like using antivirus, using strong passwords, limiting access derived from FAR 52.204 21.
  • It’s relatively straightforward and self attested you do an annual self assessment and affirm you’ve implemented the basics. No third party auditor needed at Level 1.
• Level 2 Advanced
  • Robust cybersecurity for companies handling CUI. It corresponds to all 110 security controls in NIST SP 800 171 covering areas like access control, incident response, encryption, etc..
  • This is the level most defense contractors will need. Assessments are required every 3 years in many cases by an accredited third party C3PAO, though some non critical programs might allow self assessments initially.
  • Either way, you must fully implement NIST 800 171 controls and formally validate it.
• Level 3 Expert
  • Elite security for a small subset handling the most sensitive CUI think defense tech R&D, critical programs.
  • It builds on Level 2’s controls and adds advanced practices from NIST SP 800 172 about 20 extra controls aimed at APTs.
  • This is no joke things like active threat hunting, network segmentation, real time monitoring. Government assessments DIBCAC audits every 3 years are required for Level 3. In other words, DoD itself will come check under the hood.

CMMC 2.0 model overview: Level 1 Foundational, Level 2 Advanced, Level 3 Expert, with the number of required controls and the type of assessment needed at each level.

• How the levels work: Each CMMC level is cumulative.
  • To get Level 2, you must also have all Level 1 practices in place; for Level 3, you need everything from Level 2 plus the extra stuff.
  • The idea is a tiered model where higher sensitivity = higher security. For example, a contract for routine parts might only require Level 1 since it’s just FCI like schedules or basic orders.
  • But a contract involving CUI say technical drawings, specifications will require Level 2. Truly critical projects, weapons, intel systems could demand Level 3.
  • And make no mistake, if a contract requires a given CMMC level, you must be certified at that level to win or even keep it. No certification, no contract.

So, in summary, CMMC is the DoD’s way of holding contractors accountable for cybersecurity. It sets clear requirements mostly based on existing NIST guidelines and forces companies to prove compliance via assessments.

This is a big shift from the old honor system approach. It’s all about raising the bar across the defense supply chain because adversaries have been exploiting weak links. Now let’s talk about why this matters and where pentesting comes into play.

Why CMMC Matters

Why all the fuss about CMMC? In a word: threats. Cyberattacks on the defense supply chain have been escalating in both frequency and sophistication. Foreign hackers often nation state actors target smaller contractors who may have weaker security, as a backdoor into sensitive DoD data.

There have been high profile cases of critical weapons data, plans, and IP stolen from DIB companies sometimes without them even realizing until much later. The DoD finally said enough is enough: CMMC was created to stop these bleeding wounds of data.

• Protecting CUI:
  • If you work with DoD, you might handle drawings, schematics, technical reports, or other CUI. CMMC ensures you implement controls to keep that data out of enemy hands.
  • For instance, requiring encryption, multi factor auth, and incident response plans. It’s about making sure even the smallest subcontractor has some basic cyber defenses.
  • One leaked document from a tiny machine shop could give adversaries an edge so the entire chain needs to be strong, not just the big primes.
• Rising cyber risk:
  • According to DoD officials, contractors face millions of intrusion attempts daily. And a 2023 DoD Inspector General audit found 8 out of 10 contractors failed to implement all required NIST 800 171 controls meaning most had holes in their security.
  • This is scary when you think about what’s at stake, think fighter jet designs or troop deployment schedules.
  • CMMC is meant to close those gaps. It forces companies to not only implement controls but also document and regularly assess them, creating a culture of continuous improvement in security.
• Contractual teeth:
  • Perhaps the biggest reason CMMC matters is that it’s effectively a gate to DoD contracts. By late 2025, new DoD contracts will include CMMC requirements. If you aren’t certified, you can’t bid or win.
  • Period. Non compliance isn’t just risking a fine; it literally takes you out of the running for business.
  • In fact, a GAO report estimated that if CMMC Level 2 were enforced immediately, over 50% of current defense contractors would be ineligible for contracts. Imagine half the industry suddenly sidelined that’s huge.
  • So there’s a survival imperative here: meet CMMC or lose your DoD revenue.
• Reputation and trust:
  • Beyond the hard contract requirements, being CMMC certified is becoming a badge of trustworthiness. It shows you take cybersecurity seriously.
  • This can help not only with DoD, but also with prime contractors picking subcontractors. Nobody wants to be the weak link.
  • Conversely, a breach or non compliance can damage your reputation for years. And let’s not forget potential legal trouble falsely claiming compliance or neglecting security could lead to False Claims Act penalties or negligence claims.
  • In short, the cost of non compliance is far greater than the cost of compliance breaches can cost millions, whereas investing in security can prevent that.

Why this matters:

• CMMC is not just bureaucracy, it's about raising the security posture of everyone in the defense ecosystem.
• It matters because the threats are real you will be targeted if you haven’t been already, and the DoD is serious about enforcing it.
• As a contractor, you stand to lose contracts, money, and credibility if you ignore CMMC.
• On the flip side, if you embrace it, you’re not only protecting national security data but also your own business continuity.
• Think of CMMC as both a shield against cyber threats and a key to unlock DoD opportunities.
• And one of the smartest ways to reinforce that shield? Regular penetration testing which brings us to the big question…

Does CMMC Require Penetration Testing?

The short answer: At CMMC Level 3, yes explicitly. At Levels 1-2, not outright by name but practically, it’s strongly recommended. Let’s break it down:

• No explicit mandate at Level 1 or 2:
  • Nowhere in the CMMC Level 1 or Level 2 documentation does it say Thou shalt conduct a penetration test every X months. So if you’re looking for a control that literally says do a pentest, you won’t find it for those levels.
  • CMMC Level 2 is essentially NIST SP 800 171, and that standard focuses on things like access controls, monitoring, vulnerability scanning, etc., but it doesn’t use the word penetration test. So strictly speaking, a pentest is not a checkbox item for Level 1 or 2.
• Level 3 includes pentesting:
  • At the highest level, CMMC brings in some additional controls from NIST SP 800 172 which are meant to counter advanced persistent threats. One of those controls, CA.3.162, effectively requires penetration testing.
  • In fact, CMMC Level 3 companies must show evidence that their systems handling CUI undergo regular penetration testing at least annually.
  • The logic is clear: if you’re in the crosshairs of APTs, you need to be actively testing your defenses. So for the elite Level 3 folks, pentesting isn’t optional it’s a must.
• So why talk about pentesting at all for Level 2?
  • Because although Level 2 NIST 800 171 doesn’t explicitly demand it, many of its requirements imply the need for rigorous testing.
  • For example, Requirement 3.11.2 calls for continuous vulnerability scanning of systems and addressing vulnerabilities found.
  • It even notes that for custom software, you may need advanced analysis like dynamic testing beyond basic scans.
  • The NIST guidance on that control explicitly mentions that red team exercises may provide additional sources of vulnerabilities to address.
  • That’s essentially a wink toward penetration testing saying, in other words, Hey, automated scans might not catch everything, consider doing more aggressive simulated attacks to really find the weak spots.
  • Similarly, another control requires you to periodically assess the security controls this is part of the CA security assessment domain.
  • While this could be a self assessment or audit, a professional pen test is one highly effective way to assess your controls in action.
• Pentesting aligns with CMMC domains: Several CMMC practice areas naturally align with doing pen tests. For instance:
  • Risk Assessment RA: CMMC requires you to identify and prioritize risks a pentest identifies real world technical risks that a paperwork review might miss, feeding into your risk assessment process.
  • System & Information Integrity SI: This domain covers flaw remediation and malware protection. Pentest results will reveal unpatched flaws or misconfigurations you need to fix flaw remediation is literally SI.1.210 in NIST 800 171.
  • Security Assessment CA: This is about routinely evaluating your security controls. Doing a penetration test is a hands on security evaluation, providing evidence that you’re testing and improving, not just ticking boxes.

The bottom line: CMMC Level 2 doesn’t say do a pentest, but it expects you to be proactive in finding vulnerabilities. You could technically meet the letter of the law with just vuln scans and self assessments, but you might miss serious issues that a pentester would catch. And if those issues lead to a breach or come up during a CMMC audit, you’re in trouble.

So while not explicitly mandated at Level 2, smart organizations treat penetration testing as a de facto requirement for solid compliance. It’s part of the spirit of CMMC: don’t wait for an attacker or an assessor to find your gaps find them yourself first.

In summary, CMMC doesn’t force every contractor to do pentests on paper, but it absolutely encourages it in practice and requires it at the top level. If you’re aiming for Level 3, start scheduling those annual pentests now.

If you’re Level 2, you’d be wise to do the same it can make the difference between passing an audit versus scrambling to fix something under a POA&M, or worse, getting breached because you thought scanning was enough.

Why You Still Need Penetration Testing for CMMC Compliance

So if CMMC might not explicitly demand a pentest at your level, why bother? Here’s the reality: compliance alone doesn’t equal security. You can technically be compliant and still get owned by a basic attack if you implemented a control poorly or missed something.

Penetration testing is like a reality check for your compliance. It ensures that all those policies and controls on paper are actually effective in the real world. Here are some big reasons you should make pentesting a priority in your CMMC journey:

• Find vulnerabilities before the bad guys do:
  • A compliance checklist might confirm you have a firewall and that you apply patches but is there a misconfigured port or an unpatched server you overlooked? Penetration testers will discover the things you didn’t even know you missed.
  • For example, they might exploit a weak default password on a router or a web application flaw that automated scanners didn’t catch. It’s far better you discover and fix these than an adversary does.
  • As the saying goes, find and fix your own weaknesses, or someone else will find and exploit them. In DoD’s world of constant threats, this is not hyperbole it’s daily life.
• Validate your controls and configurations:
  • CMMC might require multi-factor authentication MFA or encrypt data at rest. You might implement those, but a pentester can test if they’re implemented correctly.
  • Maybe you set up MFA but an attacker can still bypass it due to a misconfiguration. Or you encrypted databases, but the encryption keys are stored in plaintext on the server true story we’ve seen!.
  • A pentest will tell you if your security controls actually work. It’s essentially a dry run for a real attack, which is invaluable feedback.
  • Many organizations discover during a pentest that some compliant control wasn’t truly effective and they can then fix that gap before an auditor or attacker catches it.
• Demonstrate due diligence in audits:
  • While an auditor might not require a pentest report, imagine being able to show them, Look, we conduct regular third party penetration tests and here’s how we addressed the findings.
  • That’s powerful evidence of a security focused culture. It proves you’re not just ticking off NIST controls for the sake of the certificate you’re actively trying to break and harden your own systems.
  • CMMC assessors especially at Level 2 with a C3PAO will ask tough questions and dig into your security posture.
  • Being able to reference pentest results can often answer those questions. It shows maturity and initiative, which could even make the audit go smoother.
  • It’s like doing extra credit on an exam not required, but definitely puts you in the good graces and covers you if any compliance control is borderline.
• Bridge the gap between on paper and in practice:
  • One could implement all 110 controls of NIST 800 171 by writing policies and configuring systems as required, and still have serious vulnerabilities.
  • Compliance tends to be binary control implemented: yes/no, whereas security is a spectrum. Are you secure enough against actual threats?
  • Penetration testing helps bridge that gap. It identifies things that compliance checks might miss e.g., an allowed exception, a human error, a logical flaw in a custom application.
  • It brings a dose of real world perspective to your security program, which is exactly what CMMC’s intent is. Remember, CMMC’s goal is not just to please auditors it’s to actually reduce risk of breaches in the DIB.
  • Pentesting is one of the best tools to achieve that goal.
• Improved readiness for DIBCAC or customer assessments:
  • If you ever have to go through a Defense Industrial Base Cybersecurity Assessment Center DIBCAC review for Level 3 or even a High Medium review at Level 2, expect a very deep inspection.
  • These assessors are experienced, and they often ask how you test your own security. Showing that you do regular pentests and vulnerability scans, etc. demonstrates you’re maintaining security between formal assessments.
  • Also, some prime contractors are starting to ask their subs for evidence of security practices.
  • Being able to say yes, we do annual pentests and here’s a sanitized summary can set you apart in a good way possibly making you a more trusted sub.
  • In contrast, if you say No, we only do the bare minimum scanning, that could raise eyebrows about your commitment.

Penetration testing isn’t explicitly on the CMMC Level 2 checklist, but it significantly elevates your compliance program. It’s like an insurance policy it helps ensure that you’re not just technically compliant but actually secure. It can save you from nasty surprises, whether that’s an attacker exploiting a hidden flaw or an assessor finding a weakness you hadn’t noticed.

For the relatively small investment compared to the potential cost of a breach or lost contract, pentesting offers huge ROI as part of CMMC prep. Think of it as moving from compliance mindset to security mindset. CMMC compliance will get you the cert; pentesting will help keep your name out of the breach headlines.

How Penetration Testing Strengthens CMMC Readiness

Let’s get specific: what exactly can a penetration test do for you in the context of CMMC? How does it directly contribute to meeting the requirements and sailing through audits? Here are some concrete ways a good pentest ties into CMMC controls and overall readiness:

• Mapping findings to CMMC controls:
  • A thorough pentest report will often categorize findings vulnerabilities by severity and sometimes map them to relevant frameworks. If you use a provider experienced with CMMC or NIST 800 171, they can map each finding to the corresponding control.
  • For example, a finding like No rate limiting on login endpoint allows brute force maps to control IA Identification and Authentication requirements. Or Missing critical patch on Windows server maps to SI.3.17.1 flaw remediation.
  • This mapping turns your pentest results into actionable compliance items you can update your System Security Plan SSP or Plan of Action & Milestones POA&M with these specifics.
  • It shows auditors that you’re continuously monitoring and improving each control area.
  • Instead of a generic we scan for vulns, you have evidence: a pentest on Jan 5 revealed a misconfigured firewall mapping to AC.1.001, which we remediated by Jan 10 here’s the proof.
  • That level of detail is gold during an assessment.
• Enhancing Incident Response IR:
  • One often overlooked benefit: running a penetration test can double as an exercise for your incident response team.
  • Did your security tools detect the tester’s activities? Did your staff recognize and respond to the simulated attack? For instance, if the pentest included a phishing simulation or a simulated malware drop, you can see if your IR procedures kicked in.
  • Maybe the SOC caught it great, that’s evidence for IR.4 incident response controls. If they didn’t, it’s a learning opportunity to improve your monitoring tying into SI.3.14.x controls about detecting and alerting on incidents.
  • Some companies even combine pentesting with a surprise incident drill: We’re under attack what do we do? This improves your actual readiness for a real incident, which is something CMMC aims for especially at higher levels.
  • Being able to demonstrate a robust incident response capability potentially honed by pen test drills will give assessors confidence in your IR plans and obviously helps you in a real crisis too.
• Continuous monitoring and improvement:
  • CMMC isn’t a one and done. You don’t want to just pass an audit and then coast for 3 years.
  • Continuous monitoring is implied you have to maintain compliance and security between formal assessments.
  • Penetration testing especially if done regularly, say annually or semi annually becomes a part of that continuous vigilance. It helps catch drift or new vulnerabilities that creep in over time.
  • For example, maybe 6 months after your CMMC audit, an IT admin misconfigures a server or a new critical CVE comes out a pentest can catch that and allow you to fix it before the next audit or before any bad actor exploits it.
  • Essentially, pentesting keeps you on your toes so you’re not just secure on audit day, but every day in between.
  • This is particularly important if you plan to go for the top tier: CMMC Level 3 expects a very proactive security posture almost a mini continuous monitoring program akin to what the feds do.
  • Regular pentesting fits perfectly into that narrative.
• Building a security culture E = Experience in E-E-A-T:
  • Beyond the technical, there’s a human aspect: when your developers, IT staff, and management see the results of a penetration test, it often galvanizes them to care more about security.
  • There’s nothing like a pentester demonstrating they can pop a shell on a critical server or retrieve some secure data to make everyone sit up and say, Whoa, we need to tighten things up.
  • This cultural shift means people start thinking about security in day to day operations which in turn helps with training AT domain, good configurations CM domain, etc.
  • An organization that regularly goes through pentests tends to develop a healthy paranoia and vigilance.
  • That mindset is exactly what CMMC’s maturity model is trying to instill moving from box checking to truly ingrained security practices.
  • When employees have first hand experience of a simulated breach, they gain appreciation for the controls and are more likely to follow them properly like not writing passwords on sticky notes, or being cautious with emails, etc..
  • This is intangible but invaluable for compliance and beyond.
• Audit confidence:
  • Finally, consider the confidence boost. If you’ve undergone a thorough penetration test or a few and remediated the findings, you can approach your CMMC assessment with much more confidence.
  • You know you didn’t just set configs to appease NIST 800 171 you actually tested those configs against skilled attackers. That means fewer weak spots for an assessor to find.
  • Your documentation can even reference pentest remediation as proof of certain practices. All of this reduces the chances of unpleasant surprises during the certification process.
  • And if an assessor asks a curveball like, How do you know your systems are effectively secured beyond just following the SSP? you have a great answer: We hire independent experts to test us, and we fix anything they find.
  • Here’s an example… That’s the kind of answer that turns a potentially adversarial audit into more of a collaborative discussion.

In summary, penetration testing turbocharges your CMMC readiness. It provides hard evidence and tangible improvements across multiple control families. It’s one thing to say we think we’re secure enough for CMMC, and another to say we had experts attack our system and we stood up to it or learned where to improve.

The latter is far more convincing. By mapping to controls, testing incident response, keeping continuous watch, building culture, and boosting audit confidence, pentesting truly strengthens your compliance posture from all angles.

What Type of Pentest You Need for CMMC

Not all penetration tests are created equal and to support CMMC compliance, you’ll want to ensure you’re covering the right bases. Depending on your environment and what data you handle, here are the key types of pentesting to consider:

• External Network Penetration Testing:
  • This simulates attacks from the internet against your outward facing assets. Think of your corporate network perimeter: firewalls, VPN gateways, external web servers, email portals, etc.
  • Why it’s needed, Most defense contractors have some internet facing footprint email, remote access, company website.
  • An external pentest checks for open ports, unpatched services, misconfigured DNS, weak perimeter defenses that an attacker could exploit to gain a foothold.
  • Under CMMC, you need strong boundary defenses SC domain an external pentest validates those.
  • For example, testers might find an old VPN appliance with a known vuln or a cloud storage bucket that’s accidentally public. Catch it and fix it now, rather than during a breach.
• Internal Network Penetration Testing:
  • This simulates an attacker who’s already inside your network think phishing victim compromise or a rogue insider and tries to move laterally and escalate privileges.
  • Why is it needed? Many of CMMC’s controls assume the attacker might get in, so how do you limit damage? Internal pentesting will evaluate things like network segmentation, user privileges, detection controls, and whether sensitive data is properly secured internally.
  • Testers might plug into your office network or VPN in and see, for example, if they can sniff passwords, access CUI shares, or compromise a domain controller.
  • This is crucial for verifying controls in areas like Access Control AC, Identification & Authentication IA, and Incident Response IR e.g., did anyone notice the suspicious internal activity? Many real breaches in the DIB start with one phished laptop, then pivot internally so you want to harden that internal environment and a pentest will show you how.
• Web Application and API Testing:
  • If your systems include custom web applications, portals, or APIs that handle CUI or FCI, you absolutely need to pentest them. Why it’s needed: Web apps are among the most common breach vectors.
  • A code may be compliant e.g., using HTTPS as required by SC controls, but still have a logic flaw or SQL injection vulnerability.
  • CMMC doesn’t list specific OWASP Top 10 issues, but if your web app leaks CUI due to a flaw, that’s a big failure.
  • Pen testers will perform application security testing on any web interfaces, especially those used by government or where sensitive data is exchanged. They’ll look for things like XSS, SQLi, access control bypass, etc.
  • If you use APIs maybe to interface with DoD systems or mobile apps, those too should be tested for auth and data validation issues. This ties into the System and Communications Protection SC and SI domains.
  • Also, if you’re using modern tech like GraphQL or single page apps, ensure the testers have expertise there those can have unique vulns.
• Cloud Security Assessments:
  • Many contractors are moving to cloud environments like Azure Government, Microsoft 365 GCC High, or AWS GovCloud to meet government requirements.
  • Cloud misconfigurations are a huge risk one mis set permission in S3 or Azure Blob and data’s exposed.
  • Why it’s needed, A cloud focused pentest will check your IaaS/PaaS configuration, identity and access management Azure AD configs, storage buckets, and even things like CI/CD pipelines if relevant.
  • They’ll attempt to escalate privileges in the cloud or exploit common weaknesses default creds, overly permissive IAM roles, etc..
  • CMMC has many cloud related considerations it’s allowed, but you must meet FedRAMP Moderate equivalent security.
  • If you’re using cloud to store CUI, get it tested ensure things like Security Groups, NSGs, bucket policies, etc., are ironclad. Also include M365/Azure AD config reviews testers can attempt things like OAuth token abuse or external sharing weaknesses which maps to Access Control and Configuration Management domains.
  • Since cloud is part of many IT environments now, it’s part of the pentest scope.
• Social Engineering Phishing Tests:
  • While not strictly required, this is a valuable add on. Many breaches start with a phish, and CMMC’s Awareness & Training AT domain expects you to train users against social engineering.
  • Why it’s useful, Running a controlled phishing campaign with proper authorization! as part of a pentest can reveal if employees might fall for a spoofed DoD email, or if they report it.
  • It tests your email filters do malicious attachments get through? and your staff vigilance. If, say, 30% of employees clicked a fake reset link that’s a wake up call to improve training.
  • Any findings here tied back to AT domain need better training or even Incident Response, did IT get alerted of the phishing test?
  • Some pentest providers offer this as part of a comprehensive security assessment. It’s not a core CMMC requirement, but it’s absolutely aligned with improving your security maturity, which is the whole point of CMMC.
  • Plus, it’s better to learn of these weaknesses via a friendly test than through an actual scam.
• Continuous or Ongoing Pentesting:
  • If you have long term contracts or just want to maintain strong security, consider a continuous penetration testing approach. This might involve quarterly testing or using a Penetration Testing as a Service PTaaS platform for ongoing assessments.
  • Why it’s useful, Threats and systems change constantly. An open port that was fine today might have a critical vulnerability tomorrow.
  • Continuous testing means you’re regularly checking your attack surface for new issues. Some companies implement automated scanning combined with periodic manual testing for the best of both worlds.
  • Continuous testing aligns with the idea of continuous monitoring in CMMC and ensures you’re always audit ready.
  • If an assessor asks, How do you maintain security over time?, you can point to a continuous pentesting regimen.
  • For SMBs this might be overkill, but medium to large contractors or those in high target areas e.g., defense tech should strongly consider it.
  • It’s like having an ongoing security guard rather than a one time security check.

Scope your pentest based on where CUI/FCI lives. If all your CUI is in one enclave or application, focus testing there though don’t ignore how an attacker could reach that enclave!. If you’ve segmented CUI in a special subnet or cloud, make sure the pentest includes trying to break that segmentation.

Essentially, align the pentest scope with your CMMC scope test the systems that are in scope for the certification and anything that could affect them.

By choosing the right types of pentests, you get the most bang for your buck: testing the areas most relevant to both security and compliance. Many contractors will end up doing a combination of the above over time.

For instance, you might do an external/internal network test one year, a web app test for your portal the next, and sprinkle in some phishing tests periodically. The goal is to cover all your bases where an attacker could strike. That way, you’re not leaving any weak link unexamined which is precisely the assurance DoD wants through CMMC.

Choosing a Pentest Provider for CMMC

When it comes to getting a penetration test, who you choose to perform it matters especially in a compliance context like CMMC. Here are some tips on picking the right provider and things to look for:

• Experience with DoD and NIST frameworks:
  • Look for providers who explicitly mention CMMC, DoD, or NIST 800 171 experience. Penetration testing for a defense contractor can be different than, say, testing a tech startup.
  • The provider should understand the sensitivity around CUI, possibly ITAR data, and the constraints of government environments.
  • Providers who have done work with federal agencies or DoD contractors will be familiar with common architectures like GovCloud, GCC High, on prem AD with CAC/PIV cards, etc.. They’ll also grok the importance of mapping to NIST controls.
  • For example, they should know what RMF or DFARS 7012 means, at least at a high level.
  • This context helps them tailor their approach and reporting to your needs.
  • Don’t be shy about asking for references or case studies in the defense sector.
• Mapping findings to CMMC controls in reports:
  • As mentioned earlier, a good pentest report for compliance should do more than list vulns. Ideally, the provider will map each finding to relevant CMMC domains or specific practice IDs.
  • For instance, if they find outdated software, they might tag it as relevant to SI.3.17 System and Information Integrity domain control for flaw remediation.
  • If they find weak passwords, that ties to IA Identification & Authentication domain. This mapping saves you a ton of effort when it comes to remediation and documentation. It directly feeds into your SSP and POA&M updates.
  • During vendor selection, ask if they provide CMMC mapped reporting or at least NIST 800 171 mapping. Providers who have done compliance focused pentesting will know what you mean.
  • Some might even provide an extra memo or spreadsheet that you can hand to auditors showing here’s how we addressed each finding and which control it bolsters.
• Thorough, human led testing:
  • There’s a lot of automated scanning tools out there, and some pentest firms overly rely on them. You want a provider that emphasizes manual, human led testing.
  • Automated tools are great for baseline vuln scanning and you likely already use them internally as part of CMMC. But the real value of a pentest is the human creativity chaining exploits, finding logic flaws, doing things a scanner can’t.
  • For example, a scanner might not realize that combining a minor info leak on one system with a weak credential on another can lead to domain admin but a skilled pentester will.
  • Human led testing is also better at avoiding false positives and focusing on impactful issues, which is important so you’re not chasing ghosts.
  • Many providers now offer a hybrid PTaaS Penetration Testing as a Service model platform plus human experts.
  • That can be fine, just ensure humans are doing the complex parts. If a proposal seems too cheap, be wary it might just be an automated scan in disguise.
  • Given the stakes securing defense data, this is not where you want a purely automated solution.
• Understanding of compliance boundaries:
  • The provider should be willing to work within any boundaries you have due to compliance.
  • For instance, if certain data is ITAR restricted, they may need to ensure testers are US Persons and data stays on US soil.
  • Or if you’ve segmented an environment for CMMC, they should avoid unnecessarily touching out of scope systems to not cause needless alarms or issues.
  • Also, a provider familiar with CMMC might help you scope the test to align with your CMMC boundary.
  • They could suggest, for example, including an assumed breach test on a corporate IT segment to see if they can jump into the CUI enclave because an assessor might check that too.
  • Essentially, they think like both a hacker and an auditor. This dual mindset is super useful.
• Reporting and remediation support:
  • Look at sample reports if you can. They should be clear and detailed, with evidence screenshots, logs for each finding.
  • Since you’ll likely show this or at least summarize it to others, it needs to be professional and understandable by both tech folks and management.
  • Also consider if the provider offers remediation guidance or retesting. Some companies will schedule a retest of high risk findings after you’ve fixed them, to confirm the fix.
  • This can be great to have documented: We found X, we fixed it, and it’s verified fixed.
  • As for remediation, the provider doesn’t have to fix it for you usually that’s on you or your IT/MSSP team, but they should be available to answer questions or clarify the report’s recommendations.
  • Since the goal is to improve security not just find problems, a collaborative provider is valuable.
• Credentials and trust:
  • Since you’re engaging them to simulate bad guys, make sure they are the good guys. Check for certifications OSCP, CISSP, etc. for team members or company credentials CREST, Cybersecurity Maturity Model Certification Registered Provider Organization maybe, etc..
  • A CMMC Registered Provider Organization RPO or a C3PAO that also does pentesting could be interesting since they deeply know compliance but make sure there’s separation of duties if the same org is advising and assessing.
  • At minimum, do some due diligence: how long have they been in business, do they have testimonials? This is partly about E-A-T Expertise, Authoritativeness, Trustworthiness.
  • You want experts who are known and trusted in the cybersecurity community. Sometimes the cheapest option isn’t the best for something this sensitive.
• Local vs remote:
  • Some pentests can be done remotely external, web apps, even internal if you provide a VPN connection.
  • Others might be on site like if they need to plug into a closed network not reachable over internet.
  • Consider logistics if you have to do on site, a provider located relatively close or willing to travel is needed.
  • During COVID times many moved to remote testing for almost everything, but for certain classified adjacent networks, on site is still required.
  • Pick a partner who can accommodate your situation.

Ask the provider if they can tailor the engagement as a CMMC readiness pentest. Some security companies have specific services for compliance readiness. This might include an additional debrief mapping to compliance, or even a mini gap analysis of your NIST 800 171 controls as they pertain to technical security.

It never hurts to ask. The best partners will be excited to help you not just get a report, but actually improve in context of CMMC.

In short, choose a penetration testing provider like you’d choose a teammate for this security journey. They should know their technical stuff and understand your compliance objectives.

When you find that fit, you’ll get far more value than just a PDF of bugs you’ll get guidance that helps you achieve and maintain CMMC compliance confidently.

Here’s the big picture: While CMMC compliance is now a must have for anyone wanting to do business with the DoD, it shouldn’t be seen as a mere checklist or hurdle.

It’s truly about upping your security game to protect some of the nation’s most sensitive data. And in that mission, penetration testing emerges as a strategic ally.

Think of it this way CMMC tells you what security measures you need, and a pentest tells you whether those measures actually work when put to the test. Even if CMMC Level 2 doesn’t outright demand a pentest, doing one and fixing what it finds can be the difference between paper secure and actually secure. It’s like practicing for the big game rather than just reading the playbook.

For DoD contractors, especially those handling CUI, penetration testing services is not an optional extra it’s a wise investment and a proactive defense strategy. It helps catch the stuff you overlooked, validates your hard work implementing controls, and shows auditors and prime contractors that you’re serious about cybersecurity.

In a world of sophisticated cyber threats, it’s your safety net and your polishing tool to keep your security sharp.

As CMMC rolls out and matures, requirements might get stricter, and adversaries definitely will. By integrating regular pentesting into your compliance and risk management program, you’re not only preparing for an audit you’re preparing for the real world attacks that CMMC is designed to thwart.

In short, penetration testing makes your CMMC compliance mean something. It turns it from a static requirement into a dynamic, ongoing process of improvement.

Don’t view pentesting as a burden; view it as an advantage. The best defense contractors will leverage it to strengthen their security and stand out in the CMMC era. By the time you’re undergoing a CMMC assessment or knock on wood facing a cyber incident, you’ll be very glad you took that extra step.

Ready to Strengthen Your Defenses?

The cyber threats of 2025 demand more than just box checking, they require real readiness. CMMC compliance is your ticket to DoD contracts, but true security is your ticket to peace of mind.

If you’re looking to validate your security posture, uncover hidden risks, or build a more resilient defense in depth, DeepStrike is here to help. We’re not just familiar with CMMC; we’ve got hands-on experience fortifying the very systems that keep our nation’s defense data safe.

Our team of seasoned practitioners can guide you through CMMC focused penetration testing and beyond, providing clear, actionable insights without the fluff. We believe in empowering your organization to not only pass audits, but also to stop real world attacks in their tracks.

Preparing for your CMMC audit? DeepStrike helps DoD contractors identify and fix vulnerabilities before they become compliance risks. Contact us today to discuss your CMMC focused penetration testing plan and fortify your path to certification.

About the Author

Mohammed Khalil is a Cybersecurity Architect at DeepStrike, specializing in advanced penetration testing and offensive security operations. With certifications including CISSP, OSCP, and OSWE, he has led numerous red team engagements for Fortune 500 companies and defense contractors, focusing on cloud security, application vulnerabilities, and adversary emulation. Mohammed’s hands-on experience dissecting complex attack chains and helping organizations bolster their defenses provides him with deep insights into both the attacker mindset and effective mitigation strategies. In his current role, he develops resilient security architectures and guides clients in the finance, healthcare, and defense sectors through improving their security postures ensuring they not only meet frameworks like CMMC, but truly excel in real world cybersecurity readiness.

FAQs

• Is penetration testing required for CMMC compliance?

• At CMMC Level 3, yes one of the advanced practices CA.3.162 effectively mandates regular penetration testing for systems handling CUI. For Level 1-2, it’s not explicitly required by the CMMC standard.
• However, CMMC Level 2 NIST 800 171 does require continuous vulnerability management and security assessments, which strongly implies that pentesting is a best practice to meet those objectives.
• Level 1-2 contractors won’t fail an audit for not having done a pentest, but it’s highly recommended, and Level 3 contractors will absolutely need to do it.

• Which CMMC level benefits the most from penetration testing?

• All levels benefit, but it becomes increasingly crucial at higher levels.
• Level 1 is very basic small companies with only FCI might just focus on simple cyber hygiene.
• Level 2 the majority of contractors handles CUI, and while you can technically comply via scans and policies, a pentest dramatically increases your confidence in security and compliance for that level.
• Level 3 basically requires it and is dealing with advanced threats pentesting and even more aggressive red team exercises are part and parcel of meeting that level’s intent.
• So, if you’re Level 2 or Level 3, pentesting moves from nice to have to should have/must have.
• Even Level 1 companies could use occasional pentests, especially if they plan to grow into handling CUI.

• How often should we conduct penetration testing for CMMC?

• There’s no one size answer, but a common practice is annually for a full scope pentest especially if you’re handling CUI. Some organizations do it right before a CMMC assessment cycle to catch issues, which is smart.
• Others, particularly larger enterprises or those in high risk categories, might do bi annual or quarterly targeted tests on different areas e.g., network one quarter, applications the next or use continuous testing services.
• If you’re aiming for Level 3, annual pentesting is a baseline, since the requirement calls for at least that.
• For Level 2, annual is a good practice, aligned with the idea of yearly self assessments think of the pentest as part of that yearly prep.
• Additionally, anytime you have major changes new system, major update, cloud migration, it’s wise to pentest that rather than waiting.
• The key is to have a regular cadence so that each year or each quarter you’re uncovering and fixing any new vulnerabilities promptly.

• Can vulnerability scanning replace penetration testing for CMMC?

• No they complement each other but are not the same.
• Vulnerability scanning which is required in CMMC is an automated process that identifies known issues missing patches, misconfigs, etc. and is something you should do frequently monthly or more.
• Penetration testing goes further it’s a manual, deep dive that can find logic flaws, chain multiple low risk issues into a high risk exploit, and simulate creative attack techniques that scanners can’t.
• Think of vuln scanning as an essential routine check up, and pentesting as a specialist conducting a thorough examination.
• Both are important. CMMC expects you to do scanning and to remediate what scans find as part of Risk Assessment RA.L2 3.11.2/3.
• Penetration testing isn’t explicitly required at Level 2, but it will find the things your scans miss and thus help fulfill the spirit of those controls.
• In practice, organizations with robust security do both: automated scanning for continuous coverage, and periodic pentests for deep assessment.

• What if a penetration test finds a serious issue will that affect our CMMC certification?

• Finding serious issues before your CMMC assessment is actually a blessing in disguise. You’ll have a chance to fix them.
• CMMC auditors generally won’t ask for your pentest reports you’re not obligated to share them, and they won’t ding you for issues that are already remediated.
• If a pentest finds a major gap say, weak access controls on a CUI database, you can treat it as a POA&M Plan of Action and Milestones item and resolve it.
• Under CMMC 2.0, you’re allowed to have certain minor POA&Ms at certification except for the highest priority controls, but something major should be fixed beforehand. The goal of pentesting is to avoid surprises during the formal audit.
• If you fix the issues, your CMMC assessor may never even know they were there they’ll just see a robust control implementation. In the unlikely scenario an assessor does find the same issue still open, then yes, it could jeopardize certification until fixed.
• But that just reinforces why doing the pentest first is smart! In short: a pentest finding isn’t a black mark it’s an opportunity to remediate in advance. Handling it proactively shows greater maturity and will only help your cause.

• We’re a small subcontractor at CMMC Level 1 or 2. Is pentesting still necessary for us?

• Smaller companies might feel pentesting is costly or overkill, but consider a few points.
• First, attackers often target small businesses in the supply chain because they’re seen as easier targets. So yes, you are at risk, especially if you grow into handling CUI.
• Second, pentesting doesn’t have to break the bank you can define a scope that fits your environment and budget e.g., test your main internet facing assets and one internal network segment. Many providers have packages for small businesses.
• Third, even at Level 1 or basic Level 2, a pentest can uncover misconfigurations that automated checks won’t catch think of it as a quality assurance for your IT security.
• If budget is truly tight, at minimum do internal vulnerability scans and perhaps a one time pentest of your most critical system.
• But ideally, as you work toward Level 2 compliance, plan for a pentest as part of that journey. It will save you headaches in the long run.
• And if you’re a small sub looking to win contracts, being able to say we undergo regular third party security testing is a plus in the eyes of primes.
• It demonstrates that even as a small business, you take security seriously which might just set you apart from competitors.