For several years, defense contractors have been preparing for the implementation of the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) program. In 2026, that preparation phase is rapidly giving way to implementation. Contractors that handle federal contract information (FCI) or controlled unclassified information (CUI) should expect CMMC requirements to appear with increasing frequency in DoD solicitations and contracts. Organizations that have delayed cybersecurity compliance efforts face growing risks, including lost contracting opportunities, proposal ineligibility, and potential False Claims Act exposure for inaccurate cybersecurity representations.

What Is CMMC?

CMMC is the DoD’s framework for verifying that defense contractors and subcontractors have implemented appropriate cybersecurity controls to protect sensitive government information. The program establishes graduated cybersecurity requirements based on the type and sensitivity of information a contractor handles. While organizations that process only FCI may be subject to basic safeguarding requirements, contractors handling CUI generally must demonstrate compliance with more extensive security controls derived from NIST standards. Unlike earlier self-attestation models, CMMC introduces independent assessment requirements for many contractors, creating a formal verification process before companies can compete for certain contracts.

Key Developments Contractors Should Understand

• CMMC Requirements Are Being Incorporated into Contracts
  The most significant development is the continued rollout of CMMC requirements into DoD solicitations and contract awards. Contractors should no longer view CMMC as a future compliance obligation. Instead, it is becoming a current business requirement for participation in the defense industrial base. A key 2026 milestone underscores this shift: Beginning November 10, 2026, the program enters its second implementation phase, in which DoD may require Level 2 certification assessments conducted by an accredited third-party assessment organization (C3PAO) in applicable solicitations and contracts, with discretion to impose the more rigorous Level 3 requirement for the most sensitive programs. Organizations pursuing DoD work should carefully review solicitations for cybersecurity clauses and certification requirements, as failure to meet applicable CMMC levels may render an offeror ineligible for award.
• Third-Party Assessments Are Becoming Increasingly Important
  Many contractors handling CUI will need to undergo assessments conducted by C3PAOs. These assessments evaluate whether an organization has implemented and institutionalized required cybersecurity practices. A “conditional” CMMC status can support award while remediation is completed, with “final” status required thereafter. However, because remediation efforts often take months to complete, contractors should avoid waiting until a certification is required for a specific procurement. A successful assessment typically requires substantial preparation, including documentation review, policy development, technical control validation, and evidence collection.
• Supply Chain Compliance Remains a Major Focus
  Prime contractors are increasingly scrutinizing subcontractor cybersecurity practices. As CMMC requirements move through the supply chain, subcontractors may encounter certification obligations even when they do not contract directly with the federal government. Prime contractors should evaluate subcontractor compliance risks and ensure that information-sharing arrangements align with applicable cybersecurity requirements. Subcontractors, meanwhile, should assess whether they receive, process, store, or transmit CUI and determine what certification level may ultimately apply.
• Documentation Matters as Much as Technical Controls
  Many organizations focus primarily on technical cybersecurity measures while underestimating the importance of written policies, procedures, system security plans, and supporting evidence. Assessment readiness requires more than implementing security technologies. Contractors must demonstrate that required controls are documented, consistently applied, and supported by objective evidence. Organizations should review their System Security Plans (SSPs), Plans of Action and Milestones (POA&Ms), incident response procedures, access control policies, and training records to ensure they accurately reflect operational practices.

Potential Legal and Enforcement Risks

As cybersecurity requirements become contractual obligations, compliance failures may create legal exposure beyond lost business opportunities. Potential risks include contract disputes related to cybersecurity representations; bid protest issues involving certification requirements; termination or suspension concerns stemming from noncompliance; False Claims Act investigations related to inaccurate certifications or attestations; and increased scrutiny during government audits and reviews. Contractors should carefully evaluate statements made in proposals, certifications, and compliance submissions to ensure they accurately reflect the organization’s cybersecurity posture.

Recommended Next Steps for Contractors

Organizations that participate in the defense industrial base should consider the following actions:

1. Determine whether the organization handles FCI, CUI, or both;
2. Identify the likely CMMC level applicable to current and anticipated contracts;
3. Conduct a cybersecurity gap assessment against relevant requirements;
4. Update policies, procedures, and system documentation;
5. Address technical deficiencies before assessment deadlines arise;
6. Evaluate subcontractor and supply chain compliance risks; and
7. Consult legal and cybersecurity professionals regarding certification readiness and regulatory obligations.

Looking Ahead

The Department of Defense continues to prioritize cybersecurity as a critical component of national security and supply chain resilience. As CMMC implementation expands, contractors that proactively address compliance obligations will be better positioned to compete for defense contracts and reduce legal and operational risks.

The transition from self-attestation to verified cybersecurity compliance represents a significant shift for the defense industrial base. Organizations that begin preparing now are likely to be in a stronger position than those that wait until certification becomes a prerequisite for a specific procurement opportunity.

If you have any CMMC-related questions or otherwise require assistance, please do not hesitate to contact Aron Beezley or Nathaniel Greeson.