Proactive CMMC Compliance for the DoD Supply Chain

A common misconception among many at the lower end of the Defense Industrial Base (DIB) supply chain is the assumption that the Cybersecurity Maturity Model Certification (CMMC) won't apply to them. Decades of successful government contracts, often without needing certifications, have fostered a sense of business as usual. But the landscape of cybersecurity for Department of Defense (DoD) contractors has fundamentally shifted, and proactive engagement with CMMC is now essential. 

The CMMC Program is the U.S. Department of Defense’s initiative specifically designed to safeguard Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) that is processed, stored, and/or transmitted during the performance of DoD contracts. The Cyber AB, which is the sole authorized Accreditation Body for the CMMC Program and a non-governmental partner of the DoD, manages its implementation to reduce digital risk to the DoD's supply chains. The CMMC Level 2 security requirements themselves are codified within NIST Special Publication 800-171, Revision 2 (NIST SP 800-171 R2). 

Here's why this is no longer something you can afford to ignore: As of January 2, 2025, The Cyber AB commenced authorizing eligible CMMC Third-Party Assessment Organizations (C3PAOs) to conduct CMMC Level 2 certification assessments. While the CMMC Marketplace will only display Authorized C3PAOs from this date, pre-authorized C3PAOs were able to enter into contractual agreements for voluntary assessments even prior to it. As of this month, the Department of Defense (DoD) officially transmitted the final CMMC rule to the Office of Information and Regulatory Affairs (OIRA) for its final regulatory review. This is the second-to-last milestone before the official CMMC phased rollout begins, and CMMC requirements start showing up in your contracts.  

With the 32 CFR Part 170 now in effect, no mandatory CMMC contractual requirements for defense contractors can take effect until the CMMC Title 48 Final Rule is approved and becomes effective. This impending rule will directly integrate CMMC into the Defense Federal Acquisition Regulation Supplement (DFARS), building upon existing clauses like DFARS 252-204-7021. 

The formal CMMC Assessment Process (CAP), published and maintained by The Cyber AB, serves as the official procedural guide for C3PAOs conducting CMMC Level 2 certification assessments. This process is designed to ensure the highest possible accuracy and consistency, and to instill trust and confidence in the CMMC Program. 

Instead of finding yourselves in a reactive scramble once compliance is officially required, consider this an opportune time to take a proactive approach. We strongly encourage you to start looking into CMMC now and consider scheduling a free consultation today. Understanding the process, preparing your System Security Plan (SSP), and confirming the availability of evidence are all crucial steps you can undertake today. 

Schedule your free consultation today.

About AXIOTROP, LLC:  

Ready to start your CMMC journey? Begin by identifying your cybersecurity gaps and building a tailored remediation budget. AXIOTROP’s mission is to make cybersecurity accessible, attainable, and sustainable for small and medium-sized businesses, so they remain competitive and poised for growth. We simplify cybersecurity by working closely with businesses to right-size their program for their needs, resulting in client retention, business expansion, and reduced risk.