October 9, 2019
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August 18, 2020
The Department of War's Cybersecurity Maturity Model Certification (CMMC) represents a major shift in how cybersecurity is enforced across the Defense Industrial Base (DIB). Rather than relying on self-attestations, contractors must now demonstrate verified cybersecurity maturity before they can bid on or perform DoW contracts.
If your organization works directly with the DoW or supports a prime contractor anywhere in the supply chain, CMMC is no longer optional. Understanding how it works and what level applies to your business is a critical first step toward compliance.
CMMC is the DoW's framework for assessing whether contractors have appropriate cybersecurity controls in place to protect sensitive government information. It was designed to address growing concerns around data breaches, supply-chain vulnerabilities, and inconsistent cybersecurity practices among contractors.
Under CMMC, organizations must achieve and maintain a specific certification level based on the type of data they handle and the risk profile of their contracts. Without the required certification, contractors may be ineligible to bid on new work or maintain existing contracts.
CMMC establishes multiple levels of cybersecurity maturity, each aligned with increasing levels of data sensitivity and risk. Contractors may only work on contracts that match or fall below their certified level.
Level 1 applies to organizations that handle Federal Contract Information (FCI), which includes basic information provided by the government to support contract performance. This level focuses on essential cybersecurity practices such as access control, password management, encryption, and basic data handling procedures. Many organizations already meet these requirements but still need certification to verify compliance.
Organizations handling Controlled Unclassified Information (CUI) must meet more rigorous requirements at Level 2. This level emphasizes documented security practices, user activity monitoring, employee cybersecurity training, secure data backups, and visitor controls. Level 2 is often considered a transitional stage toward more advanced compliance requirements.
Level 3 builds on prior controls and introduces more comprehensive cybersecurity planning and governance. Contractors must demonstrate consistent policy enforcement, routine security assessments, enhanced authentication measures, incident response planning, and ongoing workforce training. This level aligns closely with NIST SP 800-171 requirements and is commonly required for higher-value DoD contracts.
CMMC applies to all DoW contractors and subcontractors, regardless of size or role in the supply chain. Certification requirements will be specified in contract solicitations, meaning contractors must achieve the required level before bidding, not after contract award.
The certification level required will vary by contract, but failing to prepare in advance can significantly delay or prevent contract eligibility.
Before pursuing certification, organizations should conduct a CMMC gap analysis and readiness assessment. This process identifies the difference between current cybersecurity practices and the requirements of the desired certification level. From there, contractors can develop a remediation plan to address gaps in controls, documentation, and processes.
Because CMMC preparation often takes several months, early planning is essential—especially for organizations seeking Level 2 or higher certification.
CMMC represents a long-term shift in how cybersecurity is evaluated within the defense ecosystem. While the framework continues to evolve, one thing remains clear: CMMC is here to stay, and proactive preparation is the best way to reduce risk and maintain eligibility for DoW work.
Organizations that begin preparing now are better positioned to meet requirements efficiently, avoid last-minute disruptions, and remain competitive in an increasingly security-driven contracting environment.
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