Updated May 2026

CMMC Gap Assessment Cost: $3.5K - $60K

Phase 1 of the six-phase CMMC certification path. The gap assessment establishes the baseline that determines remediation scope, budget, and timeline. Skipping it almost always costs more downstream.

Gap assessment cost by company size

Company sizeRPO / consultant feeInternal hours absorbedLoaded total cost
Under 50 employees$3,500 - $10,00040 - 80$8K - $18K
50 - 200 employees$10,000 - $25,00080 - 200$18K - $45K
200 - 500 employees$25,000 - $45,000150 - 300$40K - $75K
500+ employees$35,000 - $60,000+250 - 500+$60K - $115K+

Loaded total cost uses BLS OEWS occupation 15-1212 (Information Security Analysts) wage anchors plus a 1.3x burden multiplier for internal labour. See methodology.

What the assessment covers

Current-state control documentation

Each of the 110 NIST SP 800-171 Rev 3 requirements is scored against current implementation: implemented, partially implemented, not implemented, not applicable.

CUI flow mapping

Tracing how CUI enters, transits, and exits the contractor environment. Identifies which systems, networks, and personnel are in scope.

Basic SPRS score calculation

Applies the DoD Assessment Methodology weight (high -5, medium -3, low -1) to unimplemented controls and produces the score that flows to SPRS under DFARS 252.204-7019.

Asset inventory verification

Confirming every system, endpoint, and SaaS environment with CUI exposure is enumerated. Missing assets are a recurring C3PAO finding.

Existing SSP review

If a System Security Plan already exists, the gap assessment evaluates whether it accurately reflects current controls and whether it would survive C3PAO scrutiny.

Remediation plan and budget

Final output: prioritised list of gaps, cost estimates per gap, recommended sequencing, and timeline to C3PAO readiness.

RPO vs independent consultant vs self-assessment

Registered Practitioner Organisation (RPO)

Cyber AB listed. Familiar with C3PAO assessment patterns. Note: an RPO that performs remediation cannot also be the assessor; verify the C3PAO of choice is independent of the RPO.

Independent cybersecurity consultancy

Cyber AB listing not required for gap assessment work (only for C3PAO certification). Confirm the consultancy has CMMC-specific experience and current NIST SP 800-171 Rev 3 familiarity.

Internal self-assessment

Free of external fees. Absorbs 80-300 internal hours. Works for Level 1 (FAR 52.204-21 17 practices) and for an early Level 2 pre-screen. Less defensible as the sole input to a C3PAO engagement.

Frequently asked questions

What does a CMMC gap assessment cover?
Five workstreams: documenting current security controls against the 110 NIST SP 800-171 Rev 3 requirements; mapping CUI flows through systems, networks, and personnel; calculating a basic SPRS score against the DoD Assessment Methodology; identifying gaps that need remediation; and producing a remediation plan with prioritised investment.
Who performs the gap assessment?
Three options. Registered Practitioner Organisations (RPOs) listed by the Cyber AB can perform pre-assessment readiness work but cannot certify (and cannot certify a contractor they have remediated, due to conflict of interest rules). Independent cybersecurity consultancies can perform gap assessments. Internal staff can self-assess, particularly for Level 1 (under FAR 52.204-21) and as a low-cost first pass for Level 2.
How much does a gap assessment cost?
Cost scales with company size and CUI scope. Sub-50-employee single-site contractors typically pay $3,500-$10,000 for an RPO-led gap assessment. Mid-size (50-200 employees) pays $10,000-$25,000. Larger (200-500+ employees) pays $25,000-$60,000. Self-assessment is free of external fees but absorbs 80-300 internal labour hours, translating to $8K-$30K of loaded internal cost.
Should I gap-assess before engaging a C3PAO?
Yes. The gap assessment defines the remediation programme, scopes the timeline before C3PAO scheduling, and prevents the expensive scenario of engaging a C3PAO before evidence is ready. Contractors who skip the gap assessment frequently discover during C3PAO readiness review that they need 6-12 months of additional remediation before they can pass; this delays the engagement and may push past the Phase 2 November 2026 deadline.
How long does a gap assessment take?
Typical timeline is 1-3 months from kickoff to final report. The on-site or remote interview phase usually runs 1-2 weeks; document review and analysis adds 2-4 weeks; report production and remediation planning adds another 1-2 weeks. Larger contractors with multiple sites or complex CUI environments can extend to 4-6 months.

Updated 2026-05-11