Why Continuous Monitoring Is Essential for CMMC Compliance
Introduction
Cyber risks evolve every day. That is why the Department of Defense (DoD) requires contractors to maintain continuous CMMC compliance, not just prepare for a single assessment. Without ongoing monitoring, organizations leave themselves vulnerable to both evolving attacks and regulatory failure.
Why It Is Required
Continuous monitoring is not optional. CMMC Level 2 directly inherits NIST SP 800-171 control 3.12.3, which requires that security controls be monitored on an ongoing basis. Assessors will expect to see evidence of this process in place.
The CMMC program also includes annual executive affirmations and multi-year reassessments. That means compliance must be maintained between formal assessments. If an organization treats compliance as a single checkpoint, it risks failing its reassessment. The consequences can include losing existing contracts, being disqualified from future bids, and suffering reputational damage.
Compliance Is No Longer a Point in Time
Threats and systems change daily: New exploits, vulnerabilities, and patches emerge constantly. Continuous monitoring ensures visibility as soon as risks arise.
Annual affirmations: Executives must attest each year that their organization remains compliant. Without continuous monitoring, there is no trustworthy basis for that signature.
72-hour incident reporting: Under DFARS 252.204-7012, contractors must report any cybersecurity incident within 72 hours. Monitoring is the only way to detect and respond within that window.
Evidence over time: Assessors want more than written policies. They require proof that controls are active and effective. Continuous monitoring generates that evidence.
Example: The Cost of Treating Compliance as a Deadline
Consider a medium-sized defense contractor that recently won a major DoD contract.
Leadership viewed CMMC as just another audit date. The compliance team implemented “continuous monitoring” in name only, focusing on documentation to pass the initial assessment but not maintaining it afterward.
A year later, the company bids on a large follow-on contract. The DoD conducts a spot check.
When asked for recent monitoring records, the company has nothing to show. As a result, it loses its certification and the new contract. Existing contracts are placed at risk and its reputation with both the DoD and the market suffers.
Conclusion
CMMC compliance is designed to ensure that contractors can withstand evolving cyber threats.
Treating compliance as a one-time exercise is a costly mistake. Continuous monitoring is not only required, it is the only way to protect both national security and your organization’s future.
