C3PAO or Self-Assessment? How to Get CMMC Level 1 Compliance Right the First Time

If you’ve been following the news about CMMC, you’ve probably seen the term C3PAO everywhere. Headlines, webinars, and consultants all talk about the need for third-party certification.

And many contractors have walked away thinking: Do I need to find a C3PAO right now to keep my DoD contracts?

The answer is clear, and it may surprise you: if you only need CMMC Level 1, you do not need a C3PAO. Level 1 is always a self-assessment.

The Myth: “Every Contractor Needs a C3PAO”

The idea that every contractor needs a C3PAO springs from the original design of CMMC 1.0, which featured five distinct certification levels, all requiring third-party assessments. This design generated real industry anxiety, especially among SMBs concerned about cost and audit complexity. In fact, the program’s critics noted that requiring certified outside audits across all levels would impose an unreasonable burden on the defense industrial base.

In response, the Department of Defense launched CMMC 2.0 in November 2021, significantly simplifying the model by reducing it to three core levels and reintroducing self-assessments for lower-risk tiers (see Wiley Law). This revision aimed to lower compliance barriers while maintaining cybersecurity integrity.

Yet the perception of “mandatory outside audits” endures. That legacy confusion, rooted in early headlines and outdated program messaging, continues to fuel the myth that all contractors need C3PAO certification, regardless of their data scope.

The Reality: Level 1 Is Always Self-Assessed

The Federal Register puts it plainly:

“Level 1 (Self) is a self-assessment to secure FCI processed, stored, or transmitted in the course of fulfilling the contract. The OSA must comply with the 15 security requirements set by FAR clause 52.204-21.” Federal Register, Cybersecurity Maturity Model Certification (CMMC) Program

At Level 1, the obligations are straightforward but non-negotiable. Contractors must do the following:

• Protect Federal Contract Information (FCI).
• Meet 15 specific controls from FAR 52.204-21.
• All 15 must be met in full (no exceptions).
• Conduct an annual self-assessment, with results submitted to SPRS.

Together, these requirements define the foundation of Level 1 compliance. The burden may appear light compared to higher levels, but each element must be addressed in a disciplined and auditable way.

The Hidden Stakes

Self-assessment is not a box-check. Unlike many compliance exercises that feel like paperwork, CMMC Level 1 Self-Assessment results in direct legal accountability.

“An Affirming Official from each OSA, whether a prime or subcontractor, must affirm the continuing compliance of their respective organizations with the specified security requirement after every assessment, including POA&M closeout, and annually thereafter. ” Federal Register, Cybersecurity Maturity Model Certification (CMMC) Program

This means:

• An Affirming Official must personally sign the affirmation.
• False claims can expose both the company and the individual to False Claims Act liability (see WilmerHale).
• Even though SPRS only requires you to submit a score, you must keep supporting documentation. As DoD notes in the scoring methodology, contractors must be able to produce evidence if challenged. Simply “submitting a score” without records leaves you exposed to audits or disputes (see <a href=“https://dodcio.defense.gov/Portals/0/Documents/CMMC/AssessmentGuideL1.pdf” target=“_blank” rel=“noopener noreferrer”

DoD CMMC Assessment Guide (PDF) )

Beyond DoD’s formal requirements, it’s also important to recognize how compliance plays out in the supply chain. Many buyers ask: “If I self-assess, how will primes or contracting officers verify my score?” Both the DoD and prime contractors can require contractors to produce compliance evidence. The DoD may request this during audits or investigations, and primes may request this as part of subcontractor due diligence. A defensible self-assessment record is critical, which is why we built Opsfolio as a centralized system of record for your compliance evidence.

Why You Keep Hearing About C3PAOs

So why does the term C3PAO dominate headlines if Level 1 never requires one?

Three reasons:

• Level 2 split: Level 2 contractors handling CUI may face a C3PAO audit every three years.
• Level 3 assessments: At the highest level, the DoD itself conducts the review, but C3PAOs are still central at Level 2.
• Scarcity headlines: As of 2024, fewer than 100 accredited C3PAOs exist. Coverage of this shortage makes even Level 1 contractors worry about bottlenecks (see CSO).

In reality, C3PAOs matter for higher levels, not for Level 1 (see DoD: About CMMC).

For Level 1, even if you hire a consultant to assist, the DoD makes clear:

“Use of a third party to assist is still considered a self-assessment…” DoD CMMC Assessment Guide

In short, C3PAOs drive the headlines, but they don’t define your obligations at Level 1. What matters for you is how to approach self-assessment correctly, without treating it as a box-checking exercise.

Doing Level 1 Right

Many contractors fall into the trap of treating self-assessment as a quick internal checklist. The truth: Level 1 is designed to be a defensible attestation, not a casual formality.

That’s why we built our CMMC Self-Assessment Tool:

• Provides detailed questions mapped directly to the CMMC Self-Assessment guidance.
• Automatically scores your answers against the 15 FAR 52.204-21 requirements.
• Generates a clear record that proves you meet the controls, not just a number in SPRS.

To take advantage of the tool, just go here and click “Start CMMC Self Assessment”.

Bottom Line

If you’re aiming for CMMC Level 1, you do not need a C3PAO. You need to:

1. Meet all 15 FAR controls.
2. Submit your self-assessment score to SPRS every year.
3. Maintain defensible evidence in case primes or auditors challenge your score.

Don’t let confusion about C3PAOs cause wasted time or money. The real job is producing a self-assessment that can withstand scrutiny.

Use our free Self-Assessment tool by going here and clicking “Start CMMC Self-Assessment.”