CUI Isn’t Your Problem. Your Governance Is.

When CMMC 2.0 challenges emerge, most contractors point to the same culprit: CUI.

The complaints are relentless: inconsistent markings, vague contract language, conflicting guidance from Primes, and a growing realization that no one is truly aligned on what qualifies as CUI once execution begins.

On the surface, those frustrations are valid. But in the field, they rarely explain why assessments stall or why readiness efforts crumble under the slightest scrutiny.

The hard truth? The real issue isn’t the data. It’s governance.

CUI is a Stress Test, Not a Root Cause

CUI has a nasty habit of forcing decisions that many organizations have spent years avoiding. Specifically, decisions about:

• Scope: What is actually in the "box"?

• Ownership: Who is ultimately responsible when things go sideways?

• Authority: Who has the final word on how data moves?

When governance is weak, these decisions happen informally, over a coffee or a quick Slack message. They get revisited repeatedly, or worse, they never land with a single accountable owner. Conversations replace documented processes. Assumptions replace formal approvals.

Over time, CUI spreads like a virus, not because your people are careless, but because you haven’t built a container to hold it. CUI doesn’t create dysfunction; it reveals it.

The Gap Between the "Signature" and the "Work"

The most dangerous governance gap lives in the "dead zone" between contract review and daily execution.

Contracts reference CUI. Programs launch at a sprint. Data begins flowing through email, shared drives, and engineering tools. But ask yourself: Is there a formal checkpoint confirming governance rules were applied before that first file was sent?

• Who validated that the contract actually introduced CUI?

• Who approved the specific systems used to process it?

• Who ensured those decisions were enforced six months after the kickoff meeting?

When these answers are "I think so," you aren’t ready for an audit. Assumptions rarely survive a CMMC assessment.

Why You Can’t "Tool" Your Way Out of This

When CUI friction peaks, the reflex is to buy a new encryption tool or roll out another "Mandatory Training" module.

These feel productive. They look good on a budget sheet. But tools only enforce the rules that governance defines, and training only explains the rules that governance owns.

Without a governing structure, your security tools will be configured inconsistently, and your training will be interpreted differently by every department. Eventually, "convenience" becomes your permanent operating procedure.

CMMC 2.0 does not measure effort. It measures control.

Governance: The Only Thing Keeping Scope in Check

Poorly governed CUI is the primary driver of "Scope Creep."

One vague decision can accidentally pull your entire enterprise email environment into the assessment scope. One "quick workaround" by an engineer can force non-essential systems under NIST SP 800-171 requirements. Suddenly, your manageable enclave has become an enterprise-wide nightmare.

Strong governance prevents this. It defines where CUI is allowed to live, requires a "hall pass" before boundaries are crossed, and documents the why so you don’t have to re-litigate the same decision every Tuesday.

What Assessors Are Actually Looking For

Assessors aren’t looking for a "perfect" record. They are looking for a functioning system.

They want to see that your organization understands its environment well enough to:

1. Detect an issue.

2. Assign responsibility.

3. Fix the problem.

4. Prevent it from happening again.

Those answers don’t come from a CUI handbook. They come from a governance structure that actually holds up under pressure. CUI is just the lens; governance is the picture.

The Bottom Line

We need to stop treating CUI as the enemy. It’s just the data we’re hired to protect.

CMMC 2.0 is a test of whether you can manage decisions, enforce boundaries, and sustain protections as program pressure increases. If your compliance feels like it’s falling apart, don't look at your data markings, look at your leadership structure.

CUI isn’t the problem. Governance is. And until governance is treated as a foundational control rather than an administrative afterthought, the "CUI problem" will never go away.

At Firstcall Federal, we help contractors move past the confusion and build the governance frameworks that make CMMC 2.0 a predictable, repeatable process. Don't wait for an assessment to find the gaps in your strategy.

Ready to take control of your scope and your strategy?

Book a Strategy Session with Our Experts

Let’s build a governance model that works for your operations, not against them.