CMMC Level 2 Compliance Strategy

Protecting CUI.
Preserving Productivity.

A practical approach to CMMC Level 2 compliance that balances security requirements with operational efficiency.

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The Landscape

CMMC Level 2: What's at Stake

CMMC is how the Department of War (DoW, formerly the Department of Defense) checks that contractors protect sensitive information. The program changed in 2026. The security requirements underneath it did not.

What is CMMC?

The Cybersecurity Maturity Model Certification is the DoW's program for verifying that contractors protect federal contract information and CUI.

  • Level 2 applies to contractors handling CUI
  • Built on the 110 requirements in NIST SP 800-171 Rev. 2
  • Three levels, from self-assessment to government-led assessment
  • Scores posted in SPRS with an annual affirmation

What is CUI?

Controlled Unclassified Information is government information that needs safeguarding but is not classified.

  • Controlled technical drawings & specifications
  • Information a contract marks or identifies as CUI
  • Export-controlled information (ITAR/EAR)
  • Government-provided data

Why Act Now?

Third-party certification is paused, but the obligation to protect CUI is in force today and is being enforced.

  • CMMC self-assessments are already a condition of award
  • DFARS 252.204-7012 still requires all 110 controls
  • Inaccurate SPRS scores carry False Claims Act risk
  • Certification is expected to return in some form

Where the Program Stands

Current as of October 2026
  1. Dec 16, 2024 The CMMC program rule (32 CFR Part 170) takes effect and defines the three levels.
  2. Nov 10, 2025 Phase 1 begins. New solicitations can require Level 1 or Level 2 self-assessments, posted in SPRS, as a condition of award.
  3. Jul 13, 2026 The DoW suspends Phase 2, which would have required third-party (C3PAO) certification starting November 10, 2026. Later phases are also on hold, and existing contracts are being modified to remove those requirements.
  4. Sep 2026 A CMMC Reform Task Force delivers its recommendations to the DoW CIO. They have not been published, and no restart date is set.
  5. Next A proposed FAR rule (June 2026) would apply NIST SP 800-171 Rev. 3 to CUI on contracts across federal agencies. Defense contracts still use Rev. 2 for now.

Whatever the reform produces, every system that touches CUI has to meet NIST SP 800-171. Keeping that footprint small pays off under any version of the program.

The Challenge

The Cost of Complying Everywhere

Applying CMMC Level 2 controls across your entire organization is expensive, disruptive, and often unnecessary. There's a smarter approach.

Full Enterprise Compliance

Every System, Every User

  • All employees subject to strict security controls
  • Every device must meet compliance requirements
  • Operational flexibility severely limited
  • Significant infrastructure overhaul required
  • Higher licensing costs across entire org
  • Major disruption to daily operations
Targeted Enclave Approach

Isolate CUI, Protect What Matters

  • Only CUI-handling staff in secure enclave
  • Most employees continue business as usual
  • Green network maintains operational flexibility
  • Leverage existing infrastructure investment
  • Compliance costs focused where needed
  • Minimal disruption to daily operations
The Approach

Two Networks. One Organization.

Separate your corporate operations from CUI handling with a purpose-built enclave. Keep business running smoothly while meeting the most stringent compliance requirements.

GREEN Network

Corporate / Unclassified
  • Existing Microsoft 365 commercial tenant
  • Standard corporate email (jordan.lee@customer.com)
  • Unrestricted collaboration & file sharing
  • Normal internet access & productivity
  • No CUI, so outside the CMMC Level 2 boundary
Conditional
Access

PURPLE Network

CUI Enclave
  • Microsoft 365 GCC High (government cloud)
  • CUI-specific email (jordan.lee@secure.customer.com)
  • Restricted data sharing & collaboration
  • Azure Virtual Desktop for secure access
  • Meets the NIST SP 800-171 requirements behind CMMC Level 2
Implementation

Simple for Users. Secure by Design.

Users seamlessly transition between networks based on their work requirements. The experience is straightforward while the security is comprehensive.

1

Start of Day

Log into GREEN network as normal for regular work

2

CUI Work Required

Click to access PURPLE environment when needed

3

AVD Session

Azure Virtual Desktop opens in browser or app

4

Work with CUI

Full compliance within the secure enclave

5

Return to GREEN

Close AVD session, back to normal work

Key Technical Components

Microsoft 365 GCC High

Separate government cloud built to DoD Impact Level 4 controls for defense contractors handling CUI

Azure Virtual Desktop

Secure remote access with no CUI on personal devices

Conditional Access

Identity-based security with device compliance checks

Dual Identity

Separate accounts for clear audit trails and access control

One Company, Two Domains

customer.com and secure.customer.com

The business keeps its main domain. CUI gets its own subdomain, hosted in a separate government cloud tenant with its own mailboxes, sign-ins, Teams, and SharePoint.

GREEN network
customer.com
Existing Microsoft 365 commercial tenant
  • Everyday email with clients, vendors, and each other
  • Teams, SharePoint, and OneDrive as they work today
  • Current devices, apps, and policies stay in place
  • Out of CMMC Level 2 scope because no CUI lives here
PURPLE network
secure.customer.com
Separate Microsoft 365 GCC High tenant
  • Mailboxes used only for sending and receiving CUI
  • Teams and SharePoint sites that hold CUI and nothing else
  • Reached through Azure Virtual Desktop, so CUI stays off local devices
  • The only environment inside the CMMC Level 2 assessment boundary

What Each Person Actually Gets

Someone who handles CUI has two email addresses and two sign-ins. Everyone else keeps the one they have today.

JL

Jordan Lee

Program Manager · everyday identity

Email jordan.lee@customer.com
Signs in to The commercial tenant, from a normal work laptop
Used for Everything that is not CUI
JL

Jordan Lee

Program Manager · CUI identity

Email jordan.lee@secure.customer.com
Signs in to The government cloud tenant, with its own password and phishing-resistant MFA
Used for CUI only, inside the virtual desktop
Day to Day

How Email Works

The rule is simple. CUI goes to and from the PURPLE address. Everything else uses the GREEN address. These are the situations people run into.

Making the Right Address Easy to Find

People who handle CUI list both addresses in their GREEN signature, so customers know where CUI belongs.

Example signature
Jordan Lee
Program Manager
(555) 010-0123
jordan.lee@customer.com
CUI only: jordan.lee@secure.customer.com
Scoping

Who Needs a PURPLE Seat

Seats follow the work, not the org chart. A person needs a PURPLE identity only if they create, receive, store, or send CUI.

Program and contract managers
Receive CUI from government customers and manage CUI deliverables
PURPLE seat
Engineers and technical staff on CUI contracts
Work with controlled technical data, drawings, and specifications
PURPLE seat
Security officer and enclave administrators
Run the enclave, review logs, and handle spills
PURPLE seat
Executives
Only if they review or approve CUI directly
Case by case
Finance, HR, and payroll
Contract values and invoices are usually not CUI
GREEN only
Sales, marketing, and general staff
No contact with CUI in their normal work
GREEN only

What That Looks Like

In an organization of 120 people, 18 need a PURPLE seat. That is about 15% of the company.

GREEN and PURPLE (18) GREEN only (102)

Illustrative numbers. Discovery sets the real count.

The Benefits

Why This Approach Works

The enclave model delivers compliance without compromise — protecting what matters while preserving operational efficiency.

Cost Efficiency

Only users handling CUI need PURPLE network licenses and infrastructure. No need to overhaul your entire organization.

Operational Flexibility

Your GREEN network continues operating without restrictive controls. Most employees experience zero disruption.

Compliance Confidence

Clear audit boundaries and documented controls make assessment preparation straightforward. Know exactly where CUI lives.

Important Context

Understanding This Presentation

What This Is

  • A conceptual overview of the enclave approach
  • An invitation to explore CMMC readiness together
  • A starting point for strategic discussion
  • Vicinity's recommendation based on industry best practices

What This Isn't

  • A binding proposal or quote
  • A complete technical specification
  • A guarantee of compliance outcomes
  • A replacement for formal assessment
  • Legal advice on specific contract clauses
Moving Forward

The Path to Compliance

A structured approach to understanding your requirements and building your compliance roadmap.

1

Discovery

Identify which business units, contracts, and users need CMMC compliance

2

Assessment

Score current state against NIST SP 800-171 Rev. 2, the basis for the SPRS score

3

Design

Size the PURPLE enclave and define implementation approach

4

Discussion

Align timeline and investment with business priorities

Questions?

Let's Start the Conversation

Your Vicinity Team

For CMMC strategy, enclave design, and next steps