If you're part of the Department of Defense supply chain, you're likely feeling the pressure of evolving cybersecurity regulations. The Cybersecurity Maturity Model Certification (CMMC) is undergoing significant changes, alongside updates to the Defense Federal Acquisition Regulation Supplement (DFARS) and Federal Acquisition Regulation (FAR). These shifts aren't just bureaucratic paperwork—they could fundamentally impact your contracts and business operations.

Why These Changes Matter to You

Let's be clear: CMMC compliance is no longer something you can push to tomorrow's to-do list. The Department of Defense has made securing the defense supply chain a top priority, and the days of extensions and leniency are behind us. Whether you're a prime contractor or a subcontractor, taking proactive steps now isn't just good practice—it's essential for your business's future in the defense sector.

Recent Developments You Should Know About

• CMMC Certification Assessments Are Here: While not yet mandatory for contracts, you can now voluntarily pursue CMMC assessments. This gives you a valuable head start, as certification will become a requirement for contract eligibility once the proposed rule takes effect.

• The Assessment Process Has Evolved: With CAP 2.0 (the updated CMMC Assessment Process), you'll find a more structured approach to obtaining certification. This standardization brings clarity to what was previously a somewhat uncertain process.

• Broader Regulatory Changes Are Coming: The new FAR rule proposal for Controlled Unclassified Information (CUI) protection signals something important—CMMC-like requirements are expanding beyond defense contractors to the broader federal supply chain.

What This Means for Your Business

If you're currently working under contracts with DFARS compliance requirements, now is the time to prepare. Once the 48 CFR rule is finalized, your business will need CMMC Level 2 certification to bid on new contracts. With assessment providers (C3PAOs) already experiencing backlogs, waiting until the last minute could put your business at risk.

Five Steps to Take Today

1. Check Your Current Standing: Review your Supplier Performance Risk System (SPRS) score—aim for the perfect 110 to demonstrate your commitment to cybersecurity and minimize risks.

2. Map Your CUI Handling: Take time to identify exactly what Controlled Unclassified Information you process and how it moves through your systems. This clarity will help you focus your compliance efforts where they matter most.

3. Get Assessment-Ready: Begin aligning your policies, procedures, and technical controls with CMMC requirements. Think of this as preparing your business for a successful certification journey.

4. Connect With Your Partners: If you're a prime contractor, start conversations with your subcontractors about compliance. If you're a subcontractor, be ready to demonstrate your cybersecurity posture to maintain valuable partnerships.

5. Schedule Your Assessment Early: With high demand for CMMC assessments, booking your slot now is simply good business sense. Think of it as securing your place in line for an essential service.

Looking Ahead Together

The compliance landscape continues to evolve rapidly. With NIST 800-171 Revision 3 on the horizon, there's real value in certifying under the current Revision 2 framework. This approach buys you three years of compliance stability, giving you breathing room as new requirements emerge.

CMMC isn't just another temporary regulation—it represents a fundamental shift in how the defense industry approaches cybersecurity. Companies that prepare thoughtfully now will build competitive advantage, protect their reputation, and avoid potential legal issues down the road.