Laying the Foundation (Part One): Conducting an Effective Gap Assessment

Why Conducting a Gap Assessment Is Critical

Before any real progress toward CMMC compliance can begin, your organization must conduct a comprehensive gap assessment. A gap assessment is a structured evaluation that compares your organization’s existing cybersecurity controls against required standards—like NIST SP 800-171—highlighting areas where improvements are needed to meet CMMC requirements. This critical step provides a clear picture of how your current cybersecurity posture compares to the controls required under CMMC 2.0. More importantly, it allows you to identify weaknesses, prioritize improvements, and begin building a structured path to certification.

A thorough gap assessment also supports compliance with DFARS 252.204-7012, which mandates that defense contractors implement NIST SP 800-171 controls when handling Controlled Unclassified Information (CUI). CMMC formalizes and validates this requirement, making the gap assessment a critical first step toward both CMMC and DFARS alignment.

Furthermore, a gap assessment isn’t just a checklist—it’s a diagnostic tool that helps you uncover where your policies, procedures, and technical safeguards fall short of the required standards. Without it, your compliance efforts are essentially guesswork, leading to wasted time, resource misallocation, or worse—failure during a formal audit.

Scoping Your Gap Assessment

Begin by identifying which level of CMMC compliance applies to your organization. This is typically determined by whether you handle Federal Contract Information (FCI), Controlled Unclassified Information (CUI), or both. From there, define the scope of your assessment by pinpointing where that data resides within your systems:

• Which systems store or process CUI or FCI?

• What departments or assets fall under compliance requirements?

Setting boundaries helps ensure the assessment is focused and aligned with business risk. To assist with this discovery process, tools like RegDOX’s Sequester can help identify sensitive documents that may require special handling. Sequester scans your system, flags potentially confidential files, and—when paired with the RegDOX Compliance Suite—automatically secures them in a compliant data room.

Incorporating solutions like Sequester early in your assessment helps ensure that no critical documents are overlooked.

Comparing Controls During the Gap Assessment

Next, evaluate your current cybersecurity practices against the official standards outlined in NIST SP 800-171A (for Level 2) and supported by the CMMC Assessment Guides. These documents provide detailed criteria for evaluating each security requirement. Use these standards to classify each control as “Met,” “Not Met,” or “Partially Met.” This structured approach adds consistency to your gap assessment and supports your compliance roadmap.

Documenting Your Findings

As you identify gaps or areas of non-compliance, document them thoroughly. Include missing controls, incomplete documentation, outdated processes, and any lack of user training. Furthermore, don’t just note what’s missing—also track where you lack supporting evidence. Audit logs, screenshots, configuration settings, training records, and access reports can all be essential proof during an assessment. The more precise your records, the easier it will be to build a strategic Plan of Action & Milestones (POA&M) in future steps.

Collaborating Across Teams for an Effective Gap Assessment

A successful gap assessment requires collaboration. Include stakeholders from IT, compliance, operations, and other departments that interact with sensitive data or systems. Their collective input creates a more realistic, comprehensive view of your cybersecurity posture, reducing the risk of overlooked issues.

Turning the Foundation into a Roadmap

By the end of the process, you should have a detailed gap analysis report highlighting what’s in place, what’s missing, and what needs attention. This report becomes your blueprint for remediation and progress toward certification.

In Week 4, we’ll explain how to translate these findings into an effective System Security Plan (SSP). This plan supports both CMMC compliance and long-term cyber resilience.

About RegDOX

At RegDOX Solutions Inc., we help defense contractors and high-security organizations simplify compliance with ITAR, EAR, DFARS, NIST SP 800-171, and CMMC requirements. Our secure, cloud-based platforms combine end-to-end encryption, access controls, and audit-ready documentation to keep your data—and your contracts—safe.

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