delivered for clients · names withheldimplementation Security operations

CMMC Level 2 and SOC 2 readiness

Cohash engineers the technical controls behind CMMC Level 2 and SOC 2. We draw the scope boundary. We map NIST SP 800-171 requirements and the AICPA Trust Services Criteria to the systems you really run. Then we close the gaps, which usually means missing MFA, access nobody reviewed or thin logging, and automate evidence from identity, PAM and SIEM tools. The assessment is your assessor's or CPA firm's job. Ours is getting the evidence ready.

  1. 01Scope and data flows
  2. 02Control mapping
  3. 03Gap remediation
  4. 04Evidence automation
  5. 05Readiness review
case-study / cmmc-and-soc2-readiness delivered
beforeControls in spreadsheets, evidence by screenshot afterEngineered controls with automated evidence
01 · SCOPE 02 · CONTROL SYSTEMS 03 · EVIDENCE 04 · ASSESSMENT CUI enclave: defined boundary CUI enclave defined boundary PLM and ERP: in-scope systems PLM and ERP in-scope systems Entra ID or Okta: MFA · Conditional Access Entra ID orOkta MFA ·ConditionalAccess IGA platform: access reviews IGA platform access reviews PAM: privileged sessions PAM privilegedsessions SIEM: logging · retention SIEM logging ·retention Evidence index: dated records per control Evidence index dated records percontrol Control map: 800-171 · TSC · owners Control map 800-171 · TSC · owners Assessor or CPA firm: CMMC · SOC 2 Type 2 Assessor or CPA firm CMMC · SOC 2 Type 2
case file

The story

Told without the client's name or anything that could identify them.

what happened

An aerospace parts supplier's IT team was asked by a prime contractor for its SPRS score and by a commercial customer for a SOC 2 Type 2 report at about the same time. Evidence for access reviews was a folder of old screenshots, and nobody could say which systems held CUI, so the assessment boundary kept growing. We traced where CUI lived across email, file shares, PLM and ERP, and moved what we could into an enclave to narrow the boundary. NIST SP 800-171 requirements and the Trust Services Criteria were mapped once to the systems that implement them, with one owner per control. After closing the MFA, access review and logging gaps, we automated evidence from Entra ID, the IGA platform, PAM and SIEM, ran a mock assessment and handed the evidence index to the compliance owner.

why it was urgent

The DFARS CMMC rule took effect on 10 November 2025. On 13 July 2026 the Department suspended Phase 2 third-party Level 2 assessments pending a review, but self-assessments, SPRS scores and annual affirmations continue. SOC 2 reports use the AICPA 2017 Trust Services Criteria with revised points of focus (2022).

problem statement
  • openA prime contractor asked for your SPRS score and nobody is sure it's right.
  • recurringA customer's security questionnaire asks for a SOC 2 Type 2 report you don't have.
  • blockedEvidence for access reviews is a folder of screenshots from last year.
  • openNobody can say which systems hold CUI. So the assessment boundary keeps getting bigger.
architecture

The estate, before and after

before
before

Before: controls in spreadsheets, evidence by screenshot

CUI was spread across email, file shares and business systems, so the boundary covered nearly everything. Control status lived in a spreadsheet and evidence was collected by hand as screenshots before each request.

Before: controls in spreadsheets, evidence by screenshot CUI was spread across email, file shares and business systems, so the boundary covered nearly everything. Control status lived in a spreadsheet and evidence was collected by hand as screenshots before each request. 01 · WHERE CUI LIVED 02 · CONTROLS 03 · EVIDENCE assumed in scope assumed in scope manual capture narrative answers attachments Email and file shares mailboxes · SharePoint PLM and ERP drawings · orders SaaS apps unknown scope Control spreadsheet status by self-report Ex Identity provider MFA gaps Screenshot folder last year's reviews Prime and customerrequests SPRS · SOC 2 report
Read the diagram as text
  1. Email and file shares → Control spreadsheet: assumed in scope
  2. PLM and ERP → Control spreadsheet: assumed in scope
  3. Identity provider → Screenshot folder: manual capture
  4. Control spreadsheet → Prime and customer requests: narrative answers
  5. Screenshot folder → Prime and customer requests: attachments
after
after

After: engineered controls with automated evidence

CUI sits inside a defined enclave, and the systems that implement controls feed a dated evidence index on a schedule. The control map ties each NIST SP 800-171 requirement and Trust Services Criterion to its system and owner.

After: engineered controls with automated evidence CUI sits inside a defined enclave, and the systems that implement controls feed a dated evidence index on a schedule. The control map ties each NIST SP 800-171 requirement and Trust Services Criterion to its system and owner. 01 · SCOPE 02 · CONTROL SYSTEMS 03 · EVIDENCE 04 · ASSESSMENT sign-in audit logs scheduled export review results session records log evidence requirement links evidence package CUI enclave defined boundary PLM and ERP in-scope systems Ex Entra ID or Okta MFA · ConditionalAccess SP IGA platform access reviews CA PAM privileged sessions SIEM logging · retention Evidence index dated records per control Control map 800-171 · TSC · owners Assessor or CPA firm CMMC · SOC 2 Type 2
Read the diagram as text
  1. CUI enclave → Entra ID or Okta: sign-in
  2. PLM and ERP → SIEM: audit logs
  3. Entra ID or Okta → Evidence index: scheduled export
  4. IGA platform → Evidence index: review results
  5. PAM → Evidence index: session records
  6. SIEM → Evidence index: log evidence
  7. Control map → Evidence index: requirement links
  8. Evidence index → Assessor or CPA firm: evidence package
results

What the client got

What changed for the client once the work was done. Described, not scored: we don't publish client figures.

  1. result 01

    A boundary drawn around where CUI really lives

    We documented how CUI flows and narrowed the in-scope systems. Sensitive work moved into an enclave, so controls didn't have to cover everything.

  2. result 02

    One control map for both frameworks

    We mapped NIST SP 800-171 requirements and the Trust Services Criteria to the same systems. Shared controls were mapped once, and each has a named owner.

  3. result 03

    Evidence is pulled, not screenshotted

    We collect identity, IGA, PAM and SIEM evidence on a schedule and file it in a dated evidence index. Over time that becomes the operating history a SOC 2 Type 2 period asks for.

  4. result 04

    The technical gaps are closed

    We put MFA on privileged and network access and scheduled the access reviews. Logging and retention meet the requirements now, and configuration baselines are in place.

  5. result 05

    The SPRS score rests on evidence

    We rebuilt the self-assessment score from system evidence and a mock assessment. The annual affirmation your counsel reviews now matches what the systems show.

what can go wrong

Risks we plan for

  1. A boundary that keeps growing

    If CUI sits in every mailbox, every system is in scope. Narrowing the boundary early cuts the work more than any tool.

  2. Policy without operation

    SOC 2 Type 2 tests whether controls worked over a period of time. Turn a control on the week before the window opens and it has no history to show.

  3. Treating the suspension as a pause

    Phase 2 assessments are suspended, not the underlying DFARS 7012 and NIST SP 800-171 obligations. Primes still ask for them.

  4. Inflated self-assessment scores

    Posting an SPRS score your systems can't back up is a legal risk. We build the score from evidence, and your counsel reviews the affirmation before anyone signs it.

ai in this move

Where AI helps, and where it needs guardrails

AI tools now appear inside both scopes. Copilots that index SharePoint can surface CUI to the wrong person, so data labels and permissions are fixed first. We use AI agents to draft control narratives and match evidence to requirements, with a person checking every mapping. Agents that touch in-scope systems get their own identities and logs, because assessors will ask about them.

forward deployed engineers →
you keep

What you're left with

We write these for your setup, and they're working documents. Your team should be able to keep things running from them long after we've gone.

  • design01

    Scope boundary and CUI data flow diagram

    yours to keep
  • evidence02

    Control map covering NIST SP 800-171 and Trust Services Criteria

    yours to keep
  • plan03

    Gap remediation plan with owners and dates

    yours to keep
  • evidence04

    Automated evidence collection with a dated evidence index

    yours to keep
  • report05

    Mock assessment findings and fixes

    yours to keep
talent and delivery · engineered controls with automated evidence

Certified engineers, wherever you need them.

Some clients want a project team, some want a couple of engineers on theirs. Either works. Onsite, nearshore or offshore, with handovers across time zones that keep things moving.

Onsite

Engineers at your sites in the US

Nearshore

Overlapping hours with US teams

Offshore

Overnight progress on your backlog

All time zones

Coverage handed over across time zones

24-hour coverage · US Central time
OnsiteUS business hours
Nearshoreoverlapping US hours
Offshoreovernight progress
Combinedhandover, not hand-off
01Do we still need CMMC work after the Phase 2 suspension?

Yes. The suspension paused third-party Level 2 assessments. DFARS 252.204-7012, NIST SP 800-171, self-assessments, SPRS scores and annual affirmations still apply, and we'd plan as if third-party assessment will return.

02Can one program cover CMMC and SOC 2?

A good deal of it. Access control, MFA, logging and change management show up in both. Scope and reporting differ, though, which is why our mapping keeps each framework visible on its own.

03Are you the assessor?

No. CMMC assessments are run by a C3PAO and SOC 2 reports are issued by a CPA firm. We engineer the controls and evidence, and legal interpretation stays with your counsel.

04How long until we're ready?

Scope size and the number of gaps that need engineering drive most of it. With SOC 2 Type 2 you also wait out the observation period, however long your auditor sets it.

next step

Planning this move?

A 30-minute working session with a senior engineer. No slides.

useful to bring
  • The platform and the version you're on
  • Where you need to get to, and by when
  • What's custom: rules, plugins, integrations
  • Any audit finding or deadline driving it