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Creating a Compliant Incident Response Plan Under the Cybersecurity Maturity Model Certification (CMMC)

November 26, 20235 min read

The Cybersecurity Maturity Model Certification (CMMC) framework is designed to protect the defense industrial base (DIB) from cyber threats. It requires contractors that work with the U.S. Department of Defense (DoD) to implement cybersecurity practices and processes at various levels of maturity. One of the critical components of the CMMC framework is incident response (IR), which outlines how organizations should handle and mitigate cyber incidents.

Understanding CMMC IR Requirements

Before constructing a compliant incident response plan, it’s important to understand the requirements set forth in the CMMC framework. The CMMC model specifies practices across different maturity levels, with each level building on the previous one. Regarding incident response, these generally involve:

  • CMMC Level 1: Basic cyber hygiene, which includes limited IR requirements.
  • CMMC Level 2: Intermediate cyber hygiene, where an organization must establish an incident response policy.
  • CMMC Level 3: Good cyber hygiene. At this level, an organization must develop and implement an IR plan that effectively responds to cyber incidents.
  • CMMC Levels 4 and 5: Proactive and Advanced/Progressive cyber hygiene, respectively. Organizations need to have a robust IR plan that can manage complex threats and share information with external stakeholders.

Developing an Incident Response Plan

Creating a CMMC-compliant incident response plan involves several detailed steps:

Establish an Incident Response Policy

  • Purpose and Scope: Define the purpose of the policy and its applicability within the organization.
  • Roles and Responsibilities: Clearly delineate who is involved in incident response and what their duties are.
  • Compliance Requirements: Address CMMC IR requirements as well as any other applicable regulations.

Conduct a Risk Assessment

  • Identify Assets: List all critical assets that could be targeted.
  • Threat Analysis: Determine probable threats and their potential impact on the organization.
  • Vulnerability Assessment: Identify vulnerabilities within systems that could be exploited in a cyber attack.

Create Incident Response Procedures

  • Detection and Analysis: Outline methods for identifying and assessing suspected incidents.
  • Containment: Detail short- and long-term containment strategies to limit the impact of an incident.
  • Eradication: Provide a method for removing threats from the environment.
  • Recovery: Describe the steps to restore systems to their normal operational state.
  • Post-Incident Activity: Explain how the organization will learn from incidents and update defenses.

Implementation and Training

  • Roll-Out: Introduce the IR plan to the organization and ensure it’s integrated into daily operations.
  • Employee Training: All relevant staff should be trained in their IR responsibilities.
  • Tabletop Exercises: Conduct simulated incidents to validate the effectiveness of the IR plan and training.

Plan Maintenance and Continuous Improvement

  • Regular Reviews: The IR plan should be reviewed periodically and updated as needed.
  • Adaptation to Emerging Threats: The plan must evolve in response to new cybersecurity threats and vulnerabilities.
  • Feedback Mechanisms: Implement ways to gather observations and suggestions for IR plan improvements.

Documentation and Record Keeping

  • Incident Logs: Maintain detailed records of all detected incidents and how they were managed.
  • Analysis Reports: Generate reports that analyze incident response efficacy and suggest improvements.
  • Audit Trails: Ensure that all incident response activities are traceable and auditable.

Testing and Auditing the Incident Response Plan


  • Tabletop Exercises: Conduct regular drills to test the plan against various hypothetical scenarios.
  • Full-Scale Simulations: For more advanced levels, perform real-world simulations of cyber attacks.


  • Internal Audits: Regularly self-assess the IR plan for compliance with CMMC requirements.
  • External Audits: Engage third-party auditors to verify compliance and identify areas for improvement.

Conclusion – Ensuring Ongoing Compliance

Creating and maintaining a CMMC-compliant incident response plan is an ongoing process that involves continuous refinement and improvement. It’s crucial to stay up to date with CMMC updates and adapt the IR plan accordingly. Organizations must ensure their plan remains aligned with the framework, providing the security necessary to protect sensitive DoD information effectively.