C3PAO Shortage Crisis: Only 83 Assessors for 118,000 Contractors
The math doesn't work.
83 Certified Third-Party Assessor Organizations (C3PAOs)
118,000 defense contractors needing Level 2 certification
Average assessment takes 2-4 weeks
You do the math. Even if every C3PAO worked non-stop, it would take years to assess everyone.
And Phase 2 starts November 2026. That's when C3PAO assessments become mandatory for most Level 2 contracts.
The capacity crisis is real. And it's getting worse.
The Current State: 83 C3PAOs vs 118,000 Contractors
As of mid-November 2025, there are only 83 authorized C3PAOs to serve the entire Defense Industrial Base.
Meanwhile, estimates show 80,000 to 118,000 contractors will need CMMC Level 2 certification by 2028.
Even assuming only 200 companies have been assessed so far (actual number as of December 2025), that leaves 117,800 contractors waiting.
If each C3PAO could assess one company per week (optimistic), it would still take 17 years to clear the backlog.
Phase 2 starts in 11 months.
See the problem?
Why C3PAO Capacity Is Limited
1. Strict Authorization Requirements
Becoming a C3PAO isn't easy. Organizations must:
- Be 100% U.S. citizen-owned
- Have ISO 9001, ISO 27001, and CMMI Maturity Level 2 or 3
- Achieve ISO 17020 certification (grace period: 27 months)
- Have completed a CMMC Level 3 assessment themselves
- Maintain minimum liability insurance
- Employ certified assessors (CCAs and CCPs)
That narrows the field significantly.
2. Individual Assessor Requirements
Even if an organization meets C3PAO requirements, they need people:
Lead Certified CMMC Assessors (CCAs) must have:
- 5 years cybersecurity experience
- 5 years management experience
- 3 years assessment/audit experience
- Baseline certification (CISSP, CISM, CISA, etc.)
- Active clearance or suitability determination
- Training and certification from CAICO (now ISACA as of Dec 17, 2025)
Finding people with that profile? Hard.
Keeping them employed at a C3PAO instead of going independent consultant? Even harder.
3. Assessment Time Requirements
A proper CMMC Level 2 assessment isn't a 1-day rubber stamp. It typically takes:
- Pre-assessment planning: 1-2 weeks
- On-site assessment: 3-5 days (depends on company size/complexity)
- Report writing and validation: 1-2 weeks
- Remediation and re-check (if findings): 2-6 weeks
Total: 2-4 weeks minimum for a straightforward assessment.
Complex environments (multi-site, legacy systems, large teams) can take months.
4. Geographic Constraints
C3PAOs aren't evenly distributed. Most are concentrated in:
- Washington DC area (defense contractor hub)
- California (aerospace/tech)
- Texas (military bases/manufacturing)
- Florida (aerospace)
If you're in Wyoming or Montana, good luck finding a local C3PAO. You'll pay travel expenses to fly one in.
ISACA Takes Over: Will It Help?
On December 17, 2025, ISACA officially became the CAICO (Cybersecurity Assessor & Instructor Certification Organization).
Their job: train and credential CMMC assessors to scale up capacity.
Will it work?
Maybe. Eventually. But not fast enough for Phase 2.
ISACA needs to:
- Build training infrastructure (courseware, instructors, testing)
- Recruit and train new CCAs and CCPs
- Support existing C3PAOs while transitioning (through March 31, 2026)
- Launch new certification programs (by April 1, 2026)
Even if they execute perfectly, training thousands of new assessors takes time. Figure 6-12 months minimum before meaningful capacity increase.
Phase 2 starts November 2026. The timeline is tight.
What This Means for Your Timeline
If you need a C3PAO assessment, here's the reality:
Current Wait Times (as of December 2025)
- Top-tier C3PAOs: 3-6 month waitlist
- Mid-tier C3PAOs: 6-12 week waitlist
- New/smaller C3PAOs: 2-4 week waitlist (but less track record)
These wait times are for scheduling the initial engagement. Add the actual assessment time (2-4 weeks) and you're looking at:
Total time from "I need a C3PAO" to "I have my certificate": 3-7 months
And that assumes:
- You're ready when they show up (no prep delays)
- You pass without major findings (no remediation delays)
- You're not competing with 100 other contractors for the same slot
Phase 2 Timeline Crunch
Phase 2 starts November 2026. At that point, most Level 2 contracts will require C3PAO assessments (self-assessment won't cut it).
If you wait until October 2026 to start looking for a C3PAO, you're screwed. Wait times will be 12+ months by then.
When to schedule: Now. Or at least Q1 2026.
Should You Self-Assess or Get a C3PAO During Phase 1?
Phase 1 allows self-assessment for most Level 2 contracts. But should you take that option?
Arguments for Self-Assessment
Pro: Cheaper ($5K-$15K for tools/consultants vs $50K-$150K for C3PAO)
Pro: Faster (no waitlist, do it when you're ready)
Pro: Less disruptive (no on-site assessors)
Arguments for C3PAO During Phase 1
Pro: Contracting officers can demand C3PAO at their discretion—if your competitor has one and you don't, who gets the contract?
Pro: Avoids the Phase 2 rush (you'll already be certified)
Pro: Third-party validation = stronger defense against False Claims Act allegations
Pro: Many primes are requiring C3PAO even during Phase 1 for flow-down compliance
The Smart Play
If you can afford it and can get on a C3PAO's schedule in Q1-Q2 2026, do it now.
Reasons:
- Beat the Phase 2 rush
- Reduce risk of being outbid by competitors with C3PAO certs
- Build relationship with C3PAO for future re-assessments (required every 3 years)
- Prove you're serious about compliance (good for primes, good for DOJ if FCA questions arise)
If budget is tight and your contracts explicitly allow self-assessment, you can self-assess for Phase 1. But start planning your C3PAO assessment for mid-2026 to be ready for Phase 2.
How to Find and Vet a C3PAO
Step 1: Check the Official Registry
The CMMC Accreditation Body maintains a list of authorized C3PAOs:
cyberab.org/marketplace
Don't hire anyone not on this list. There are consultants claiming to be C3PAOs who aren't authorized. Their assessments won't count.
Step 2: Check Availability and Location
Call 3-5 C3PAOs and ask:
- What's your current waitlist?
- Do you serve [your state/region]?
- What's your typical assessment timeline start to finish?
- How many assessments have you completed?
Step 3: Ask for References
Legit C3PAOs will happily provide references from past clients (with client permission).
Ask references:
- How long did the assessment actually take?
- Were there unexpected costs?
- How responsive was the C3PAO?
- Would you use them again?
Step 4: Understand the Pricing
C3PAO fees vary based on:
- Company size (number of employees handling CUI)
- System scope (how many systems/locations)
- Complexity (legacy tech, multi-site, cloud/hybrid)
- Travel costs (if not local)
Typical ranges:
- Small shop (1-10 people): $30K-$60K
- Medium shop (11-50 people): $60K-$100K
- Larger organizations (50+ people): $100K-$250K+
Get quotes from multiple C3PAOs. But don't just pick the cheapest. A bad assessment is worse than an expensive one.
Step 5: Verify Their Assessors
Ask:
- How many Lead CCAs do you have?
- Will the same team do my assessment or do you rotate?
- What's their industry background (manufacturing? aerospace? software?)
You want assessors who understand your business. A CCA with aerospace background will understand machine shop IT challenges better than one who only knows software companies.
Red Flags to Watch For
Red Flag 1: "We Can Get You Certified in 2 Weeks"
Bullshit.
Even if you're 100% compliant, the assessment process takes 2-4 weeks minimum. Anyone promising faster is either lying or planning to rubber-stamp you (which the CMMC-AB will catch and revoke).
Red Flag 2: "You Don't Need to Fix Anything Before We Assess"
Also bullshit.
If you're not compliant, you'll fail the assessment. Any reputable C3PAO will do a pre-assessment or gap analysis first to help you get ready.
Red Flag 3: "We Guarantee You'll Pass"
No one can guarantee that. The C3PAO's job is to objectively assess your compliance, not to help you pass.
If they're guaranteeing results, they're not independent. And the CMMC-AB will revoke their authorization when they find out.
Red Flag 4: "We're Not on the Official List But We're Authorized"
Nope. If they're not on the cyberab.org registry, they're not authorized. Period.
What If You Can't Get a C3PAO Slot?
If every C3PAO you contact has a 6+ month waitlist and your contract deadline is sooner, you have three options:
Option 1: Self-Assess (if allowed)
Check the contract. If it says "CMMC Level 2 (Self)" is acceptable, do a self-assessment.
But document it thoroughly. If the contracting officer has doubts, you'll need to show your work.
Option 2: Get in Line for a C3PAO and Disclose Timeline
Some contracts allow you to be "in process" at award as long as you have a credible completion date.
Schedule the C3PAO assessment, get a written engagement letter with dates, and submit that with your bid. Explain you'll be certified by [realistic date].
The government might accept it. Or they might award to someone already certified.
Option 3: Skip This Contract, Target the Next One
If the contract requires "CMMC Level 2 (C3PAO)" and you don't have it and can't get it in time, you're ineligible.
Don't waste time bidding. Use that time to get certified so you're ready for the next opportunity.
The Long-Term Solution
The only real fix is more C3PAOs.
ISACA's taking over assessor training helps. But the bottleneck is also:
- ISO 17020 certification (takes 12-18 months for new C3PAOs)
- Finding qualified assessors (limited talent pool)
- Economic incentives (C3PAO margins aren't huge, so growth is slow)
Some predictions:
- By mid-2026: 120-150 C3PAOs (modest growth)
- By 2028: 200-300 C3PAOs (best case scenario)
That's still not enough for 118,000 contractors. Which means:
Wait times will remain long through 2028.
Get in line early.
The Bottom Line
83 C3PAOs can't serve 118,000 contractors.
If you need CMMC Level 2 certification, schedule your C3PAO assessment now. Not next quarter. Not "when we're ready." Now.
Phase 2 is 11 months away. Wait times are already 3-6 months. By mid-2026, they'll be worse.
Don't let lack of C3PAO availability cost you contracts.
Next Steps:
Ready to start the process? Take our 2-minute quiz to confirm your CMMC level.
Not sure if you're ready for a C3PAO? Read our NIST 800-171 priority guide to see what you need to fix first.
Want to understand Phase 2 timing? Check out our Phase 2 timeline guide.
