CMMC compliance for software contractors. Done in 60 to 75 days, not six months.
A complete CMMC v2.0 documentation package built for software development firms holding DoD contracts: source code as CUI, secure SDLC, CI/CD attestation, SBOM under EO 14028, and government developer access scoped for an assessor. Built by a Cyber AB Registered Provider Organization with four CMMC RPs on staff.
DoD software firms, mission systems integrators, and government developer shops.
If your company writes software under a DoD contract, integrates mission systems, or stands up a development environment for a federal customer, CMMC is in your pipeline. Source code is CUI in most defense software contracts.
This page is built for software development firms in the Defense Industrial Base. It covers direct DoD prime contractors writing custom mission software, subcontractors and integrators embedded in larger primes (Lockheed Martin, Northrop Grumman, Raytheon, BAE, General Dynamics IT, Leidos, Booz Allen, SAIC), commercial software vendors selling regulated products into DoD environments, and professional services firms placing developers on federal customer accounts under Time and Materials or labor-hour contracts.
It also covers software-adjacent shops that ship code as part of a larger deliverable: avionics firmware vendors, ground-system integrators, simulation and modeling houses, AI/ML services firms with DoD agencies as customers, and the growing list of small product companies winning OTA, SBIR Phase II/III, and AFWERX awards. If your repos hold customer data, mission data, or derived engineering data tied to a federal program, you are in scope.
Common buyer signals we see in this space:
- A prime contractor has updated your master subcontract with the new CMMC clause and DFARS 252.204-7012, plus DFARS 252.204-7019 / 7020 / 7021.
- A federal customer is asking for an SBOM (Software Bill of Materials) under Executive Order 14028 and the OMB M-22-18 attestation for federally used software.
- You are running a government-owned, contractor-operated (GOCO) development environment, or a contractor-owned environment with government developer accounts, and the customer is asking for proof of cyber posture.
- Your CI/CD pipeline produces signed builds, and the customer wants attestation that the build pipeline itself is access-controlled, change-managed, and integrity-checked.
- You hold engineering data, mission system code, or test data that meets the definition of Controlled Unclassified Information (CUI), most commonly Controlled Technical Information (CTI) or Defense (DCNI-O).
Source code, build pipelines, and dev access are the CMMC scope.
The 110 NIST 800-171 controls in CMMC Level 2 do not pick a vertical. For software shops, the CUI is hiding in places ordinary IT-only consultancies miss: Git, container registries, build agents, and developer laptops.
Source code as CUI
For most DoD software contracts, the customer-funded source code is CUI / Controlled Technical Information. Repos in GitHub, GitLab, Bitbucket, or Azure DevOps that hold mission code, derived engineering data, or customer-funded IP have to live inside the CMMC boundary.
Build pipeline scope
CI/CD runners, container registries, artifact stores (Artifactory, Nexus, Harbor), signing keys, and deployment targets are all in scope. Many shops scope only the developer laptop and miss the build server entirely; the assessor will not.
Secure SDLC requirements
NIST 800-171 family 3.13 and 3.14, plus the new SP 800-218 Secure Software Development Framework (SSDF), govern how your team writes, reviews, builds, and ships code. SAST, SCA, secret scanning, code review approvals, and reproducible builds all become evidence.
SBOM and EO 14028
Executive Order 14028 and OMB M-22-18 require federal customers to demand attestation that producers follow secure development practices and produce a Software Bill of Materials. Your CMMC SSP names the attestation, the signing key, and the SBOM tooling.
Government developer access
Many DoD software contracts require government developer accounts inside your environment. Federated identity, separation of duties, audit logging on every privileged action, and offboarding the moment a clearance lapses, are all CMMC-relevant evidence.
Software supply chain
Open source dependencies, third-party libraries, and base container images are an in-scope supply-chain concern. SCA tooling, vulnerability triage SLAs, and container provenance (Sigstore, in-toto) become documented controls inside the SSP.
The CMMC package, scoped for a software shop.
Branded, editable, yours forever. Formatted to DIBCAC and C3PAO expectations. The software-specific items (source repo controls, CI/CD attestation, SBOM, SSDF mapping, government developer access) are baked into the SSP and CUI boundary documents.
System Security Plan (SSP)
110 NIST 800-171 control narratives with software-shop asset inventory: source repos, build agents, registries, signing keys, developer laptops, federated identity provider.
CUI boundary for source code
Network diagrams that draw the boundary around Git, build runners, artifact stores, container registries, and deployment targets. Federated identity boundary documented.
SPRS score
Calculated SPRS score with a control-by-control breakdown. The number primes look at before they release a follow-on task order.
POA&M with SDLC gaps
Plan of Action & Milestones with the gaps software shops actually have: untagged dependencies, missing SAST gates, signing keys on developer laptops, off-boarded contractor accounts still in Git.
14 security policies
One policy per NIST 800-171 family (3.1 through 3.14), branded to your firm. Reuse for SOC 2, ISO 27001, FedRAMP Moderate, and StateRAMP audits.
14 operational procedures
Step-by-step procedures: code review approvals, secret rotation, build pipeline change management, government developer onboarding and offboarding.
SSDF / EO 14028 attestation
An OMB M-22-18 self-attestation template and a Secure Software Development Framework (NIST 800-218) mapping that your federal customer's contracting officer can accept.
SBOM and supply-chain narrative
An SBOM tooling narrative (CycloneDX or SPDX), vulnerability triage SLAs, container signing process, and dependency-update cadence written into the SSP.
Assessment readiness checklist
The day-of punch list: which engineering manager attends the interview, which build pipeline gets walked through, which evidence (signed commits, code review records) the assessor opens.
Output formats: PDF, editable Word, HTML, CSV, ZIP. Branded with your logo. No platform lock-in.
From scoping to assessor handoff in 60 to 75 days.
A predictable, productized engagement built around a six-step scoping wizard, with deliverables and sign-offs at each gate.
Scoping & CUI boundary
60-minute working session. We map your DoD contracts in flight, the prime flow-downs you have signed, your repos and registries, and the CUI boundary across development, CI/CD, and deployment.
Asset and data inventory
Source repos, build runners, artifact stores, container registries, signing keys, developer laptops, federated identity, and any government-account access into your environment.
Gap analysis & SPRS
All 110 controls scored against your shop, plus an SSDF mapping. SPRS calculated. POA&M drafted with software-specific gaps and remediation timeline.
Documentation build
SSP, 14 policies, 14 procedures, SSDF / EO 14028 attestation, SBOM narrative, all branded and reviewed by our four CMMC RPs.
Mock walkthrough
Tabletop assessment with our CMMC RPs, including the questions a C3PAO will ask your engineering manager, your DevSecOps lead, and your IT lead.
Assessor handoff
Evidence repository organized, interview prep done, assessment readiness checklist signed. We hand the package to your C3PAO.
Pick your level. Get a fixed price, fixed timeline.
Three productized packages. Fixed prices, fixed timelines, third-party assessment fees disclosed up front so the total budget is transparent before you sign.
Foundational (FCI)
- 17 control narratives + SSP
- Policies and procedures package
- SPRS attestation prep
- 21-day delivery
Advanced (CUI)
- SSP + POA&M + SPRS score
- 14 policies + 14 procedures
- 110 control narratives
- SSDF / EO 14028 attestation
- 60 to 75 day delivery
Expert
- L2 baseline + 24 NIST 800-172 controls
- DIBCAC-led assessment readiness
- Architecture and threat modeling
- Custom timeline
What counts as CUI in a software shop.
Use this as a starting point during the scoping call. We will refine each row against your active contracts, your data rights clauses, and any DD Form 254 on file.
| Artifact | Likely CUI category | Where it lives |
|---|---|---|
| Customer-funded source code (DoD contracts) | Controlled Technical Information (CTI) | GitHub Enterprise, GitLab, Azure DevOps, Bitbucket, internal Git |
| Mission system configuration and data | CTI, Defense (DCNI-O) | Configuration repos, Ansible / Terraform, deployment manifests |
| Build pipelines and signing keys | CTI (process), CUI (key material) | Jenkins, GitHub Actions, GitLab CI, HashiCorp Vault, AWS KMS |
| Container images and artifacts | CTI | Artifactory, Nexus, Harbor, ECR, GHCR |
| Customer test data, sample inputs | CTI, sometimes Privacy / PII | Test data shares, S3 buckets, fixture repos |
| Government developer credentials and access logs | Defense (DCNI-O), CUI Privacy | SSO logs, IDP audit, ticketing systems |
| Engineering analysis and modeling outputs | CTI | Notebooks, internal data lakes, simulation results |
| Vulnerability and pen-test reports against your code | CTI, OPSEC | Security tools (SAST/DAST), report stores, ticketing |
If your C3PAO finds a doc gap, we fix it free.
Every ComplianceArmor CMMC engagement carries the Petronella Technology Group Audit-Ready Promise. If a C3PAO assessor identifies a gap in any artifact we produced, we fix it at no charge within 30 days. If a CMMC Level 2 assessment fails because of our documentation work, we refund 50% of our fee. The package is yours forever, in editable native formats, with no subscription and no DRM.
Important disclosure. Petronella Technology Group, Inc. is a Cyber AB Registered Provider Organization (RPO). The independent CMMC Level 2 assessment required for certification is performed by a Cyber AB Authorized C3PAO under a separate engagement, priced separately from this package. Only the Cyber AB and the U.S. Department of Defense issue CMMC certificates. Petronella Technology Group does not perform certified assessments and does not promise assessment outcomes.
CMMC questions DoD software shops ask first.
Is our source code really CUI?
For most DoD software contracts, yes. The standard DFARS 252.227-7013 / 7014 data rights clauses, plus the contract Statement of Work, will tell you which deliverables the government has rights in. When the customer is funding the code or claiming Government Purpose Rights, the source qualifies as Controlled Technical Information, a CUI category. Internal product code your firm developed at private expense and licenses to the government typically does not. We separate the two during the scoping call so the CMMC boundary contains only what actually has to be in scope.
How do DFARS 252.204-7012 clauses end up in software development contracts?
Whenever the contract anticipates the contractor handling Covered Defense Information (CDI), the contracting officer is required to include DFARS 252.204-7012. For software firms, that almost always means source code, mission data, government test data, or design and engineering data is in scope. The 7012 clause requires NIST 800-171 implementation, cyber incident reporting to DC3 within 72 hours, and flow-down to subcontractors handling the same data. Once the CMMC final rule fully phases in, DFARS 252.204-7021 layers the CMMC Level requirement on top.
Does our CI/CD pipeline have to be inside the CMMC boundary?
If your build pipeline produces or transports CUI, yes. That includes Jenkins or GitHub Actions runners that compile customer-funded code, container registries that hold customer-deliverable images, signing infrastructure (Sigstore, Cosign, KMS-backed signing keys), and deployment runners that push to government environments. Many shops scope only the developer laptop and the source repo, then get caught by the assessor when the build server turns out to be sitting in a different VPC with a different identity boundary. We document the entire pipeline as one contiguous CUI boundary or, in some cases, as a clearly partitioned environment with documented controls at the boundary.
What does Secure SDLC look like in CMMC terms?
NIST 800-171 family 3.13 and 3.14, plus the new NIST SP 800-218 Secure Software Development Framework (SSDF), set the bar. In practice that means: branch protection and pull request approvals, mandatory SAST and SCA gates with documented triage SLAs, secret scanning, secure base images, signed commits and signed artifacts, reproducible builds where feasible, and a documented vulnerability disclosure path. We map your existing tools (whichever you use) onto the SSDF practices and write the SSP narrative around it. We do not force you to switch tools.
What about CI/CD attestation and EO 14028?
Executive Order 14028 and OMB Memorandum M-22-18 require federal agencies to obtain a self-attestation from software producers that they follow secure software development practices, plus an SBOM in many cases. The attestation form was published by CISA. We provide an OMB M-22-18 attestation template, an SBOM tooling narrative (CycloneDX or SPDX), and an SSDF mapping, all written so a contracting officer's representative can accept it without follow-up questions.
How do we handle government developer access into our environment?
Many DoD contracts require government developer accounts inside the contractor's environment. Treat them like any other privileged user: federated identity into your IdP (typically with the customer's CAC-backed login), separation of duties, audit logging on every privileged action, conditional access policies based on device posture, and offboarding the same business day the contract option is not exercised or a clearance lapses. We document the federation pattern, the audit retention period, and the offboarding runbook in the SSP.
How does CMMC interact with FedRAMP for our SaaS product?
FedRAMP and CMMC overlap heavily but do not replace each other. FedRAMP authorizes a cloud service offering for federal use under NIST 800-53. CMMC governs the contractor's own internal environment under NIST 800-171. If you run a FedRAMP Moderate authorized SaaS that DoD customers use, your customer-facing system inherits most controls from FedRAMP, but your internal development, build, and engineering environment still falls under CMMC. We map the inheritance so you do not double-document, and we identify which CMMC controls remain your responsibility regardless of FedRAMP authorization.
How long does this take, and what does it cost?
CMMC Level 1 from $6,997 flat, 21-day delivery, no third-party assessor required.
CMMC Level 2 documentation package from $24,997 flat, 60 to 75 day delivery. The required C3PAO assessment fee runs $30K to $50K and is engaged separately. We disclose that on every pricing card so the total budget is transparent up front.
CMMC Level 3 is custom-scoped after a discovery call. DIBCAC-led assessment is government-administered.
Stop authoring the SSP. Start the CMMC assessment.
Schedule a 30-minute scoping call. We will walk through your DoD contracts, your repos, your build pipeline, and quote your engagement on the call.
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