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AI in the professions

AI for CMMC: Compliance Assistance Without Compliance Fiction

Dr. Beza LefeboVP, AI Strategy and Workforce Development. 1 min read

Cybersecurity Maturity Model Certification readiness can be difficult for small defense contractors.

The organization must understand its information environment, identify where Federal Contract Information and Controlled Unclassified Information reside, define the assessment scope, implement security requirements, prepare a System Security Plan, gather evidence, remediate gaps, and maintain continuing compliance.

Artificial intelligence can help with much of this work.

An AI system can map requirements to policies, identify missing evidence, compare implementation statements with technical artifacts, organize screenshots, draft procedures, and prepare control owners for assessment interviews.

However, AI also creates a dangerous temptation. It can generate documentation that looks more mature than the organization’s actual cybersecurity program.

A polished policy does not prove that a control is implemented. A well-written SSP does not establish that multifactor authentication is enforced, audit logs are reviewed, accounts are attributable, or CUI is protected.

Current DFARS requirements connect CMMC status with the contractor systems that process, store, or transmit covered information. They also require continuing affirmations and specify the validity periods associated with different CMMC assessment levels.

Objective evidence remains essential.

AI must never fabricate screenshots, invent ticket numbers, create nonexistent meeting records, or state that a security requirement is satisfied when the evidence shows otherwise. That is not compliance assistance. It is compliance fiction.

The best use of AI is to expose the truth more quickly. It should help organizations identify what is implemented, what is missing, who is responsible, and what evidence is required to close the gap.

AI can reduce the administrative burden of compliance, particularly for small contractors with limited staff. It cannot assume the responsibility of the affirming official, system owner, assessor, or executive leadership.

Sources and further reading

  1. Electronic Code of Federal Regulations. “32 CFR Part 170, Cybersecurity Maturity Model Certification Program.” Current.
  2. Acquisition.gov. “DFARS 252.204-7021, Contractor Compliance with CMMC Level Requirements.” Current.

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