CMMC Contractor Exposure: What You're Actually Signing
Most contractors think of their CMMC self-assessment as a compliance form. They fill it out. They submit it. They move on.
But the document they're signing is not a compliance form. It's a federal representation.
When you submit your self-assessment score and affirm compliance, you are making a statement to the United States government about the state of your cybersecurity controls. That statement is attached to every contract you hold or bid on that references defense cybersecurity requirements. The government reserves the right to verify that statement by accessing your facilities and systems directly. This is not a one-time filing. It is a standing claim that remains active for as long as your contracts are active.
The exposure this creates is not theoretical. It's structural.
First: you are signing for implementation, not documentation. The attestation doesn't say "we have policies that describe these practices." It says the practices are implemented. The difference between those two statements is the documentation gap, and it's the gap where liability accumulates.
Second: you are signing for the present, but the claim persists into the future. If your systems were compliant on the day you signed but drifted out of compliance six weeks later, the claim still says you're compliant. You haven't updated it because nobody told you to re-check. But the government's position is that your score should reflect your current state, not your historical state.
Third: if you signed, you are rarely the person who verified. The consultant produced the documentation. The IT provider configured the systems. But you, if you signed, are the one who bears the legal exposure.
This creates a structural bind that several contractor groups have described in different ways. You have the most at stake and the least technical ability to verify what you're certifying. You're trusting a chain of providers, each of whom has a financial incentive to say the systems are ready. And if the systems aren't ready, your signature is the only thing the government needs.
The contractors who've recognized this exposure are approaching it differently. They're not just asking whether their consultant says they're compliant. They're asking whether they can prove compliance independently of their consultant, asking whether their systems generate evidence of enforcement rather than relying on documentation of intent.
The ones who haven't recognized it are still signing based on what they've been told. And what they've been told may have been true once. The question is whether it's still true today.