Do I need a vCISO for CMMC?

There's no CMMC requirement to have a Chief Information Security Officer. What CMMC does require is that specific control practices are implemented and evidenced — and someone has to own that internally.

For a small defense contractor (5–30 employees) without a dedicated security lead, a fractional or virtual CISO (vCISO) is worth engaging during the prep phase. Typical scope: 4–6 months, 10–20 hours per week, running the gap analysis, POA&M authorship, policy adoption, and evidence coordination through to the C3PAO assessment.

Cost range: $8k–$18k per month for a competent vCISO in the CMMC space, or $32k–$108k for a full engagement.

Where a vCISO earns their fee: interpreting NIST 800-171 controls in your specific environment, negotiating with C3PAOs, and running the assessment day. Where they don't: repetitive evidence collection, policy templating, and ongoing control monitoring — Scarlet Comply automates most of that.

The right pattern for most SMBs: use a vCISO for the assessment sprint, then transition to tooling + a part-time internal owner for ongoing compliance maintenance. This cuts annual security overhead by 60–70% after year one.

If you're at Level 1 (self-attestation), a vCISO is usually overkill. Scarlet Risk plus 5–10 hours per week of internal ownership is enough for a defensible SPRS score.