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A lot of contractors are trying to check the boxes for CMMC, but sometimes they expect their C3PAO to do more than it’s supposed to. This creates confusion, missed timelines, and frustration on both sides. Knowing what a C3PAO actually does—and what they don’t—is the key to a smooth CMMC assessment process.
C3PAOs Dictate Remediation
Some contractors think that once a C3PAO shows up, they’ll be handed a to-do list of how to fix everything. But that’s not how it works. C3PAOs don’t tell organizations how to close gaps—they only confirm whether the requirements have been met. The responsibility to figure out what needs to be fixed and how to fix it belongs to the contractor. This often becomes clearer as teams go through the CMMC level 2 requirements and realize no one’s there to do their homework for them.
Think of the C3PAO like a referee, not a coach. They show up to call the plays, not to guide your practice. So if a contractor is still working on aligning with the CMMC compliance requirements, they need to handle remediation internally or with the help of a Registered Provider Organization (RPO)—not expect their C3PAO to act as a fixer. The assessment process is about showing up prepared, not scrambling for direction during the game.
C3PAOs Guarantee Compliance
There’s a big myth that if you hire a C3PAO, you’re automatically going to pass your CMMC assessment. That’s simply not true. A C3PAO doesn’t “grant” compliance—they review evidence, interview staff, and decide whether the organization meets the requirements. If the systems and policies don’t meet CMMC level 1 or CMMC level 2 requirements, then the result is a failure, no matter who performs the assessment.
Contractors need to enter the assessment already compliant, not hoping the C3PAO will “help them get there.” The role of the C3PAO is to remain neutral and objective throughout the CMMC assessment. Passing is based on preparation, documentation, and execution—not who you hire to assess you. It’s a pass/fail process, and no amount of good intentions can replace solid evidence of compliance.
C3PAOs Are Responsible for System Security
Here’s where things get blurry for many defense contractors. Just because a C3PAO is checking your system doesn’t mean they’re responsible for keeping it secure. That duty stays with your internal IT or external cybersecurity provider. A C3PAO comes in to validate—not to protect. They assess what’s in place and how it lines up with the CMMC compliance requirements, but they don’t set up your firewalls or patch your systems.
Imagine asking a health inspector to cook your meals. It doesn’t work like that. If your organization is handling Controlled Unclassified Information (CUI) and aiming for CMMC level 2 requirements, then you’re expected to maintain a secure environment long before a C3PAO shows up. They’re checking that your work holds up—not babysitting your network.
C3PAOs Provide Consulting Services Beyond Assessment
One of the most common mix-ups? Assuming a C3PAO will give advice before or during the CMMC assessment. Contractors often treat C3PAOs like consultants, expecting tips and recommendations during the process. But the rules are strict—C3PAOs cannot consult on fixing issues before or while assessing you. That’s a clear conflict of interest and can invalidate the assessment.
If your organization needs help preparing for CMMC level 1 requirements, that’s when you call in an RPO or cybersecurity advisor. C3PAOs are there to judge, not guide. They’re like exam proctors—they don’t give hints, and they won’t tell you if you’re answering the question wrong. Their job is to measure, not mentor. Mixing up those roles can cost time, money, and credibility.
C3PAOs Are Interchangeable Commodities
All C3PAOs must follow the same assessment guidelines, but that doesn’t mean they’re all the same. Each has a different style, background, and approach. Some specialize in specific sectors like aerospace or manufacturing. Others may have more experience interpreting controls in unique environments. While the requirements are standard, how assessments are conducted can vary based on the C3PAO’s expertise and communication style.
This means contractors shouldn’t treat choosing a C3PAO like picking a name from a hat. It’s worth researching who’s a good fit based on your business type and existing cybersecurity posture. CMMC assessment preparation is already intense, and working with someone who understands your environment can make it smoother. It’s not about favoritism—it’s about alignment.
C3PAOs Handle All Documentation
Many contractors breathe a sigh of relief once they schedule their assessment, thinking, “The C3PAO will take care of the rest.” But documentation is still your job. The assessor will review what you provide—system security plans, policies, procedures, and evidence of implementation. If those materials aren’t in order, the C3PAO can’t “fill in the blanks” for you.
For example, if a company is aiming for CMMC level 2 requirements but doesn’t have up-to-date access control policies or audit logs, no amount of explaining will cover that gap. Documentation is proof, and without it, the best technical setup still fails. Contractors need to be organized, thorough, and ready to show what they’ve done. A strong paper trail is as important as a secure system in meeting CMMC compliance requirements.
