Approaching executions of CMMC Implementation
The Defense Department (DoD) has embarked on a three-year phased implementation plan to bring the Cybersecurity Maturity Model Certification (CMMC) to full capacity and maturity. This ambitious cybersecurity conformity regime, which has been germinating at the DoD since 2019, aims to protect Controlled Unclassified Information (CUI) handled by defense contractors.
The CMMC requirements timeline for the defense industry is as follows:
- The CMMC Final Rule, which was published on October 15, 2024, and became effective on December 16, 2024, marks the legal foundation of CMMC.
- Starting early 2025, CMMC requirements began appearing in DoD contracts in a phased rollout across the Defense Industrial Base (DIB).
- The final 48 CFR rule, which formally includes CMMC requirements in contracts, is expected to be published after review, most likely resulting in CMMC language appearing in DoD contracts as early as October 2025.
- The deadline for full CMMC compliance for all relevant organizations, including Managed Service Providers (MSPs) and Managed Security Service Providers (MSSPs), is October 1, 2026.
- The DoD is rolling out CMMC in phases with enforcement increasing over time; the goal is full implementation by October 2025, though some contracts may include requirements even later.
To operationalize certification and audits on this timeline, the DoD has implemented regulatory frameworks and oversight bodies. The Cyber Accreditation Body (CAB), for instance, is responsible for accreditation and has established processes for third-party assessments by authorized CMMC Third Party Assessment Organizations (C3PAOs), particularly for CMMC Levels 2 and 3 requiring independent audits.
Over 80,000 defense contractors are expected to be impacted, with assessments aligned to NIST 800-171 and NIST 800-172 cybersecurity standards depending on the CMMC level required. The CAB has accredited 455 Cybersecurity Maturity Model Certification (CMMC) Certified Assessors (CCAs), including 300 "lead CCAs". Approximately 2-3,000 CCAs are estimated to be needed to fully scale the CMMC requirements as the defense industrial base grows.
The DoD has also taken steps to ease the compliance bar for CMMC. They are piloting a shared service approach with cloud service providers and managed service providers to help contractors meet the CMMC requirements.
Matthew Travis, chief executive of the Cyber Accreditation Body, stated that the publication and implementation of the CMMC acquisition rule will mark the starting line of the grand odyssey of CMMC. Contractors are advised to accelerate preparation immediately to meet these impending obligations.
It's worth noting that there hasn't been a clear economic incentive to get certified as a CCA until recently, due to the unclear timing of the CMMC requirements and the cost of training and exam. However, with the phased implementation strategy, the DoD aims to ensure that CMMC can be administered efficiently without creating a backlog.
In conclusion, the Defense Department's phased implementation of CMMC is a significant step towards enhancing cybersecurity within the defense industry. Contractors are encouraged to prepare for CMMC compliance to secure their positions in the defense market.
- As the Defense Department implements the Cybersecurity Maturity Model Certification (CMMC), technology will play a crucial role in operationalizing the certification and audits process, with the Cyber Accreditation Body (CAB) relying on third-party assessments by authorized CMMC Third Party Assessment Organizations (C3PAOs).
- With over 80,000 defense contractors expected to be impacted by the CMMC requirements, technology, specifically the NIST 800-171 and NIST 800-172 cybersecurity standards, will be integral to ensuring compliance and protecting Controlled Unclassified Information (CUI) handled by these contractors.
