TL;DR: CMMC 2.0 turns access review, audit evidence, and lifecycle discipline into prerequisites for defence supply chain work, with Level 2 mapping to all 110 NIST SP 800-171 requirements and Level 3 adding NIST SP 800-172 controls, according to Zluri. The practical lesson is that certification readiness depends on identity governance maturity, not point tools or one-time cleanup.
Editorial analysis by NHI Mgmt Group, based on content published by Zluri: “CMMC Compliance: An In-depth Guide”.
Key questions
Q: How should IAM teams support CMMC compliance in practice?
A: They should treat access governance as evidence generation.
Q: Why do access reviews matter for CMMC readiness?
A: Access reviews matter because CMMC readiness depends on proving that only authorised people can reach CUI and that access changes are controlled.
Q: What breaks when identity hygiene is treated as a one-time cleanup project?
A: Access reviews, group governance and ownership drift apart, so the programme produces compliance activity without reliable control.
Practitioner guidance
- Map access reviews to CMMC scope Identify which identities, groups, and entitlements can reach FCI or CUI, then align review cadence to the certification level and assessment evidence you must produce.
- Document entitlement decisions and exceptions Record who approved access, which roles are in scope, what was removed, and what exception remains open so the compliance trail survives assessor review.
- Tie remediation to a tracked POA&M workflow Convert each certification gap into an owner, due date, and closure record so remediation evidence remains visible across the full compliance cycle.
Bottom line: CMMC compliance makes identity governance part of defence supply chain assurance, so access scope and review evidence matter directly to certification.
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CMMC compliance turns identity governance into an evidence problem, not a tooling problem. The article is explicit that organisations must continually update and improve cybersecurity measures to stay compliant, which means identity controls have to be provable over time. For defence supply chain teams, that shifts the centre of gravity from feature selection to governance evidence, and access reviews become a certification input rather than an administrative chore.
A few things that frame the scale:
- Nearly 60% of IT leaders cite restrictive cost and complexity as a weakness of legacy identity governance, according to the 2025 State of Identity Governance Report.
A question worth separating out:
Q: What should organisations prioritise first for CMMC-related identity controls?
A: They should prioritise scope definition, access review cadence, and documented remediation ownership. Those three elements determine whether identity governance can support audit evidence for Level 2 and Level 3 obligations.
👉 Read our full editorial: CMMC compliance and identity governance: what teams need to know