CMMC May Be Delayed. Your Cybersecurity Obligations Are Not.
For many organizations in the Defense Industrial Base (DIB), the evolving timeline for the Cybersecurity Maturity Model Certification (CMMC) has created uncertainty. As implementation dates shift and certification requirements continue to roll out, some contractors are asking whether they should postpone their compliance efforts.
The answer is no.
While CMMC certification requirements continue to phase into Department of Defense acquisitions, many contractors already have cybersecurity obligations under their existing contracts.
What Contractors Are Required to Do Today
Organizations Seeking Certification (OSCs), both prime contractors and subcontractors, may already be required to meet cybersecurity requirements depending on the FAR and DFARS clauses incorporated into their contracts.
For organizations handling Federal Contract Information (FCI), applicable FAR requirements align with the foundational security practices represented by CMMC Level 1, including an annual self-assessment.
Organizations handling Controlled Unclassified Information (CUI) under DFARS 252.204-7012 and related DFARS clauses are expected to implement the security requirements contained in NIST SP 800-171. Depending on the contract, future CMMC Level 2 requirements may require either a self-assessment or an assessment by an authorized third-party assessment organization (C3PAO).
Although the timing of CMMC certifications has evolved, the responsibility to protect sensitive government information has not been achieved.
A Pause in Certification Is Not a Pause in Cybersecurity
Waiting for certification requirements to become mandatory can create unnecessary risk.
Implementing security controls, documenting policies, collecting evidence, training personnel and remediating deficiencies all take time. Organizations that postpone these activities may find themselves scrambling when certification requirements are included in future solicitations or contract renewals.
Instead, organizations should use this time to strengthen their cybersecurity posture and build a mature, defensible compliance program.
Think of It Like Filing Your Taxes
A helpful analogy is preparing your taxes.
You can prepare and file your taxes yourself, but if questions arise later, you’re responsible for supporting the decisions you made and the documentation behind them.
Working with a CPA doesn’t eliminate that responsibility. It provides experienced professionals who understand the rules, help identify issues before they become problems, and support you if your work is scrutinized.
Cybersecurity compliance works much the same way.
Organizations can perform self-assessments, but experienced advisors can help ensure the assessment is accurate, well documented and supported by objective evidence. That foundation becomes invaluable if your compliance is ever reviewed by a contracting officer, auditor or future CMMC assessor.
How We Can Help
Rather than waiting for certification deadlines, organizations can continue making meaningful progress today.
Our team helps contractors:
- Assess their current cybersecurity posture.
- Identify gaps against NIST SP 800-171 and CMMC requirements.
- Prioritize remediation efforts.
- Develop the documentation and evidence needed to support compliance.
- Prepare for future CMMC assessments with confidence.
The goal isn’t simply to “pass an assessment.” It’s to establish a cybersecurity program that protects sensitive information while standing up to scrutiny.
Looking Ahead
CMMC is changing how contractors demonstrate cybersecurity, but it is not changing the fundamental expectation that organizations safeguard government information.
Contractors that continue investing in compliance today will be in a much stronger position tomorrow; whether that means responding to a contract requirement, completing a self-assessment or preparing for a formal CMMC certification.
The timeline may shift, but the obligation to protect government information does not.
Find Out Where You Stand
Whether you’re just beginning your CMMC journey or evaluating your current cybersecurity posture, understanding your readiness is the first step.
Our CMMC Level 2 Readiness Check is a complimentary online assessment designed to help defense contractors gauge their preparedness for CMMC Level 2. In just a few minutes, you’ll receive a high-level view of your organization’s readiness and identify potential areas for improvement before certification becomes a contractual requirement.
Take the CMMC Level 2 Readiness Check and start building a more confident, defensible path toward compliance.
Contributors
Bryan Bell, Principal
Bradley Taylor, Director
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