Many DoD contractors think CMMC Level 2 and ITAR are two different problems. One feels like cybersecurity. The other feels like export law. In reality, they are tightly connected, and missing that connection is costing contractors real work.
If your company touches technical data, this matters more than you think.
The Big Confusion Most Teams Have
Here is the key fact many teams miss: export controlled technical data under ITAR is also CUI. That means if you handle ITAR data, CMMC Level 2 applies.
CMMC Level 2 ITAR overlap is not optional. It is built into how the rules work.
CMMC focuses on protecting CUI using NIST 800-171 ITAR aligned controls like access control, encryption, logging, and monitoring. ITAR focuses on who is allowed to see that data and where it can be stored or shared.
When teams only focus on one side, problems start.
Where Contractors Are Struggling
Many DoD contractors rush to meet CMMC Level 2 deadlines and forget about ITAR rules at the same time.
Common issues we see include:
- ITAR technical data stored in non compliant cloud systems
- Foreign nationals having access to export controlled CUI
- Assuming CMMC self assessment equals ITAR compliance
- Using tools that meet cybersecurity needs but ignore export control
- Missing documentation that ties ITAR and CMMC together
These are not rare mistakes. They are happening every day across defense contractor compliance programs.
What This Can Cost You
When ITAR and CMMC compliance are handled separately, the risks add up fast.
- Failed or delayed CMMC Level 2 audits
- Export control violations that trigger legal exposure
- SPRS scores that do not match reality
- Being screened out during market research
- Lost trust from primes and government buyers
- Contracts delayed, reduced, or lost
In some cases, companies think they are compliant until an audit or review proves otherwise.
The Shift That Changes Everything
The solution is not more tools. It is better alignment.
CMMC and ITAR should be planned together from the start.
CMMC answers the question, “How is the data protected?”
ITAR answers the question, “Who is allowed to access it and where can it go?”
When both questions are answered at the same time, compliance becomes clearer and easier to manage.
This is where strong DoD contractor ITAR cybersecurity programs stand out from reactive ones.
What Success Looks Like
Contractors who align ITAR and CMMC compliance early see strong results.
- Clear identification of export controlled CUI
- Proper access restrictions tied to citizenship rules
- Cloud environments that meet both security and ITAR needs
- Cleaner CMMC Level 2 assessments
- Reduced risk of export violations
- Faster approvals and stronger teaming confidence
Instead of scrambling to fix gaps, these teams move forward with confidence.
Start With the Right Checklist
If you want to reduce risk and stop guessing, start with a checklist built for this overlap.
Our CMMC Level 2 Audit Checklist helps you:
- Identify where ITAR technical data exists
- Align NIST 800-171 ITAR controls with CMMC Level 2
- Prepare audit evidence the right way
- Reduce compliance gaps before they cost you contracts
Download the CMMC Level 2 Audit Checklist and make sure your compliance program covers both CMMC and ITAR the way DoD expects.
This overlap is real. Getting ahead of it now is much easier than fixing it later.
