CMMC Level 1 Doesn't Require Special Government Software
One of the most persistent myths about CMMC: you need to buy special government-approved software to be compliant.
Vendors love this myth. It sells expensive products. But for Level 1, it's simply not true.
CMMC Level 1 can be achieved with standard business tools you probably already own. No "CMMC certified" products required. No government-specific cloud. No specialized security software. Your current technology stack likely works—you just need to configure it correctly and document what you're doing.
Let's break down what you actually need versus what vendors want you to think you need.
The Myth vs. Reality
The Myth: CMMC compliance requires special government software, CMMC-certified products, and expensive specialized tools.
The Reality: Level 1 requirements focus on security practices, not specific products. The requirements say things like "limit system access" and "protect against malicious code"—they don't specify which brand of software you must use.
This confusion often comes from mixing up Level 1 and Level 2 requirements. Level 2 does have stricter requirements around cloud services (FedRAMP authorization, GCC High for Microsoft). But Level 1? Standard business tools work fine.
What Actually Works for Level 1
Email and Productivity: Standard Microsoft 365 or Google Workspace
You don't need GCC High (Microsoft's government cloud) for Level 1. Regular Microsoft 365 Business works. So does Google Workspace.
GCC High costs significantly more—often 2-3x the price of commercial Microsoft 365. It's designed for handling CUI under Level 2 requirements. If you're only handling FCI at Level 1, you're paying for protection you don't need.
That said, you still need to configure your email and productivity tools properly:
- Enable multi-factor authentication (strongly recommended even if not strictly required)
- Set appropriate sharing permissions
- Use strong password policies
- Control who has admin access
The tool is standard. The configuration matters.
Antivirus: Windows Defender Works
You don't need to purchase enterprise antivirus software. Windows Defender (built into Windows 10 and 11) consistently performs well in independent testing and meets Level 1 requirements.
What matters:
- It's enabled and running on all systems
- Real-time protection is turned on
- Definitions update automatically
- Regular scans are scheduled
If you prefer third-party antivirus like Malwarebytes, Bitdefender, or Norton—that's fine too. But you don't need to spend money if Windows Defender is properly configured.
Firewall: Standard Business Routers Are Fine
You don't need a $10,000 enterprise firewall. A properly configured business-grade router from Cisco, Ubiquiti, Netgear, or similar manufacturers includes firewall functionality that meets Level 1 requirements.
What matters:
- The firewall is enabled (not bypassed)
- Unnecessary ports are closed
- Default passwords have been changed
- Someone has reviewed the configuration
Even many consumer-grade routers have adequate firewall capabilities for Level 1—though business-grade equipment is recommended for reliability and features.
File Storage: Standard Cloud or On-Premises
You don't need FedRAMP-authorized cloud storage for Level 1. Standard OneDrive, Google Drive, Dropbox Business, or on-premises file servers work.
What matters:
- Access permissions are set correctly
- You know who can access what
- Files are backed up
- You can control and revoke access when needed
FedRAMP authorization becomes relevant for Level 2 when handling CUI. For Level 1 with FCI, standard business cloud services are acceptable.
Password Management: Any Reputable Tool
If you use a password manager (recommended), any reputable option works—Bitwarden, 1Password, LastPass, Dashlane, or even browser-based managers. There's no requirement for a specific "government-approved" password manager at Level 1.
What About "CMMC Certified" Products?
You may see vendors marketing products as "CMMC certified" or "CMMC compliant." Be skeptical.
There's no official CMMC product certification program. Products aren't certified—organizations are. A vendor claiming their product is "CMMC certified" is using marketing language, not an official designation.
What matters is whether a product helps you meet requirements, not whether it carries a compliance label. A $50 cross-cut shredder meets the media sanitization requirement just as well as an expensive "secure document destruction system."
Where Level 2 Differs
To be clear: Level 2 does have stricter technology requirements. If you're pursuing Level 2 certification, you may need:
- GCC High or GCC for Microsoft services handling CUI
- FedRAMP-authorized cloud services for certain workloads
- FIPS-validated encryption for protecting CUI
- More sophisticated logging and monitoring tools
But these are Level 2 requirements for handling CUI. Level 1 contractors handling only FCI don't need this level of infrastructure.
Know your level before you buy. Vendors won't always make the distinction clear.
What Level 1 Actually Requires
Level 1 isn't about specific products. It's about practices:
- Access Control: Know who can access your systems and limit it appropriately
- Identification & Authentication: Verify users are who they claim to be (passwords)
- Media Protection: Destroy information properly when disposing of equipment
- Physical Protection: Control physical access to your systems
- System & Communications Protection: Protect your network boundary
- System & Information Integrity: Use antivirus and keep systems updated
You can meet all 15 requirements with:
- Computers you already own
- Software you already have
- A shredder
- Locked doors
- Basic policies and documentation
The investment is primarily time, not technology.
Configuration and Documentation Matter More Than Products
Here's the real message: it's not about buying new stuff. It's about:
- Configuring what you have correctly. Enable the security features in your existing tools. Set proper permissions. Turn on automatic updates. Use the firewall that's already in your router.
- Documenting what you're doing. Write down your policies. Keep records of who has access. Log your security practices. Create evidence you can point to.
Most small businesses fail Level 1 not because they lack the right products, but because they haven't configured existing tools properly or documented their practices.
A business with standard Microsoft 365, Windows Defender, and a basic firewall—all properly configured and documented—is more compliant than a business with expensive specialized tools sitting misconfigured and undocumented.
Don't Overbuy
Before purchasing anything marketed as a CMMC solution, ask:
- Is this required for Level 1, or only Level 2?
- Can I meet this requirement with tools I already have?
- What specific requirement does this product address?
- Is there a simpler, less expensive alternative?
Some purchases make sense—a decent shredder, a business-grade router, maybe a password manager subscription. But "CMMC compliant" enterprise software suites costing thousands of dollars? Probably not necessary for Level 1.
Invest your money where it matters. For most Level 1 contractors, that's time spent on configuration and documentation—not new software.
Assess What You Actually Have
Not sure if your current tools meet Level 1 requirements? CMMCheck walks you through each requirement with simple questions about your existing setup. You'll quickly see what's working, what needs configuration changes, and what (if anything) you actually need to purchase.
Try CMMCheck and find out whether your current tools are enough.
This article is part of CMMCheck's Plain English CMMC Level 1 Guide, a complete resource for small businesses navigating DoD cybersecurity requirements.
