DoD Contractors Prepping for CMMC Compliance
The Cybersecurity Maturity Model Certification (CMMC) has been a major focus for contractors within the Defense Industrial Base (DIB) and Department of Defense (DoD). Since its introduction in 2020, there has been confusion about its requirements, applicability, and enforcement timeline. Now, CMMC has evolved into its second version, reducing five levels to three, and is on the path to full implementation. Defense contractors will need to make a decision on how they are going to achieve and maintain their CMMC compliance status as audits begin.
Why Was CMMC Introduced?
The DoD established CMMC to protect sensitive defense-related information from increasing cyber threats. Over the past decade, adversaries have exploited cybersecurity gaps in the DIB, leading to the unauthorized disclosure of Controlled Unclassified Information (CUI). CMMC ensures that defense contractors implement adequate security measures to protect this data, thereby strengthening national security.
What is CUI?
CUI is sensitive but unclassified information that requires safeguarding due to government regulations. It includes data such as defense schematics, technical manuals, contract specifications, and export-controlled information. Ensuring proper handling of CUI is crucial to maintaining national security and protecting defense operations from foreign adversaries.
Where Does the CMMC Rule Stand? It’s Final for CMMC Compliance
It has taken several years to finalize the CMMC rule with many contractors wondering when these requirements will begin to show up in their contracts. In October of 2024, the final rule for CMMC entitled 32 CFR was published with an effective date of December 16, 2024. Now, in 2025, many contractors are beginning the audit process.
While finalized, CMMC will be implemented in several phases:
Phase 1: Begins with the effective date of the CMMC Title 48 rule, anticipated in early to mid-2025. During this phase, Level 1 and Level 2 self-assessment requirements will be included in applicable solicitations and contracts as a condition of award.
Phase 2: Starts one calendar year after Phase 1. Level 2 third-party assessments conducted by Certified Third-Party Assessment Organizations (C3PAOs) become a condition for contract awards.
Phase 3: Initiates one calendar year after Phase 2 begins, involving government-led Level 3 assessments for contracts handling the most sensitive Controlled Unclassified Information (CUI).
Phase 4: Arrives one year after Phase 3, marking full implementation with CMMC requirements included in all applicable DoD solicitations and contracts, including option periods.
How Should DoD Contractors Respond To CMMC?
Given the finalized CMMC framework, defense contractors must act quickly to achieve compliance. Failure to comply can result in contract loss, financial penalties, or legal consequences. Here’s what organizations should focus on:
1. Conduct a CMMC Gap Assessment
Evaluate your current cybersecurity posture against NIST 800-171 requirements (the foundation of CMMC Level 2). Identify gaps and develop a remediation plan.
2. Implement Key Cybersecurity Controls
Adopt required security measures, including:
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Multi-Factor Authentication (MFA)
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Data Encryption
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Incident Response Plans
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Continuous Monitoring and Logging
3. Choose the Right Compliance Partner
Working with a Managed Security Service Provider (MSSP) experienced in CMMC can simplify compliance. Under CMMC terminology, these providers are known as External Service Providers (ESP) and must also meet compliance standards.
CMMC compliance is not just an IT decision, but a business one.
CorpInfoTech helps contractors achieve and maintain CMMC compliance through our TAS for CMMC Compliance solution. We passed our CMMC Level assessment with a perfect 110 score. This allows to us streamline compliance efforts with pre-certified controls that flow down to your business.
By utilizing TAS for CMMC Compliance, your organization will inherit 200+ of the 320 objectives required by CMMC. It is important to understand that a self-assessed MSP will still be within in scope of your audit, meaning that any failure on your service providers side will reflect on your compliance status.
CorpInfoTech has gone through the process and understands the complexities of compliance. Let us help you achieve your compliance goals!
CorpInfoTech passed our CMMC Level 2 Assessment with perfect 110 score. We are among the first MSPs to pass our CMMC Level 2 Assessment.
