The Department of Defense (DoD) is moving forward with the Cybersecurity Maturity Model Certification (CMMC) 2.0 program, transforming cybersecurity compliance from a future consideration into an immediate requirement for the Defense Industrial Base (DIB).
Experts stress that government contractors must prioritize their compliance roadmaps today, as the official phased rollout is not a grace period.
Failure to obtain the necessary certification for handling Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) will soon jeopardize a company’s contract eligibility.
Deltek Senior Manager for Cloud Solutions Michael Greenman recently presented five key takeaways in a webinar, providing defense contractors with crucial insights on navigating CMMC 2.0 enforcement, costs, and supply chain pressure.
1. Phased Rollout Does Not Mean Deferred Compliance
Many government contractors (GovCons) mistakenly believe the multi-year phased rollout of CMMC 2.0 grants them extended preparation time, particularly for Level 2 compliance. Experts caution against this thinking.
While the full implementation will take time, DoD contracting officers retain the ability to insert any level of CMMC requirements into solicitations starting as soon as the final rule takes effect. This means a company could lose out on a new contract tomorrow if it lacks the required certification status or a compliant security posture.
GovCons must immediately treat CMMC as a non-negotiable business requirement that dictates cyber maturity and contract access.
2. Certification Requires Significant Time and Financial Investment
Achieving CMMC Level 2, the standard for most contractors handling CUI, demands substantial resources. Deltek’s annual Clarity report highlighted that companies spend between $50,000 and $250,000 simply to prepare for the Level 2 assessment. Furthermore, the assessment itself can cost small businesses an estimated $100,000.
The process of implementing the NIST SP 800-171 controls, conducting a gap analysis, and achieving compliance typically takes 12 to 18 months. Since all CMMC certifications are valid for only three years and require annual affirmations, organizations must budget not only for the initial upfront costs but also for recurring assessment fees and continuous system maintenance to maintain their competitive edge.
3. False Starts Are Increasing Assessment Timelines
Contractors rushing to meet deadlines frequently experience costly “false starts” in their certification journeys. These occur when Certified Third-Party Assessment Organizations (C3PAOs) find critical violations during the official audit, forcing the company to pause the process, remediate the deficiencies, and restart the assessment.
A common pitfall involves the improper handling of data, such as ITAR data, which transforms into CUI when associated with a DoD contract. Companies must conduct a thorough CUI boundary analysis and mock audit before engaging an official assessor to avoid wasting time and significant financial resources.
4. Prime Contractors Drive Supply Chain Certification
Large prime contractors are not waiting for the DoD to enforce CMMC requirements across the entire supply chain; they are enforcing it themselves. Primes are increasingly telling their subcontractors and suppliers that their CMMC status determines eligibility for participating in critical defense programs.
They now require suppliers handling FCI or CUI to demonstrate compliance. For small and mid-sized contractors, achieving the appropriate CMMC level is now a prerequisite for maintaining their position in the supply chain, as primes view non-compliant subs as unacceptable risk vectors.
5. Cloud Service Providers Face Stricter FedRAMP Requirements
The growing reliance on cloud computing means that contractors using external services to store or process CUI must ensure their Cloud Service Providers (CSPs) meet stringent security standards.
CSPs must hold a Federal Risk and Authorization Management Program (FedRAMP) Moderate or higher authorization, or prove FedRAMP Moderate equivalency.
Achieving this equivalency requires CSPs to demonstrate 100% compliance with the latest FedRAMP Moderate security control baseline and provide comprehensive security documentation, including a System Security Plan and a Security Assessment Report.
GovCons must establish a shared responsibility model with their CSPs, ensuring that all third-party systems accessing CUI are certified through the Cyber AB accredited process.
