Organizations, especially defense contractors, must prepare for Cybersecurity Maturity Model Certification (CMMC) compliance before it’s mandatory. Proactive cybersecurity measures ensure regulatory adherence, data protection, national security, and company credibility. By being proactive, your company displays a commitment to cybersecurity standards and avoids potential penalties. Smooth transitions, risk mitigation, and industry reputation depend on early preparation.
Need help with CMMC compliance? Get in touch with a cybersecurity expert.
Key Differences Between the CMMC and CMMC 2.0 Frameworks
As you may be aware, CMMC is shifting from its original iteration to CMMC 2.0. The two noteworthy differences in these frameworks are in the Plan of Action and Milestones and waivers. What do these changes entail?
Changes to Plan of Action and Milestones (POA&Ms)
Plans of Action and Milestones (POA&Ms) address any possible cybersecurity gaps. They outline specific actions, target dates, responsible teams, and descriptions of the actions to be taken. POA&Ms demonstrate your company’s commitment to continuous improvement and compliance.
CMMC 1.0 did not allow POA&Ms, while CMMC 2.0 will allow them. The Department of Defense will establish a minimum score requirement to support certification with POA&Ms.
Changes to Waivers
Waivers are authorizations for organizations to temporarily deviate from specific cybersecurity requirements. To obtain a waiver, organizations must provide detailed justifications and mitigation plans. However, waivers aren’t long-term solutions, and organizations are still accountable for meeting regulatory requirements.
CMMC 1.0 didn’t provide a waiver provision. However, CMMC 2.0 will allow companies to apply waivers to entire CMMC requirements instead of individual cybersecurity practices. Note, though, that this will be allowed only in select mission-critical instances and upon senior leadership approval.
To request a waiver, the DoD program office must submit a justification package that includes a specified timeline and an associated risk mitigation plan. Timelines for compliance with CMMC are imposed on a case-by-case basis.
Who Needs to Be Concerned with CMMC 2.0?
All Department of Defense (DoD) contractors and subcontractors need to be aware of the CMMC 2.0 compliance requirements, regardless of their previous compliance with the earlier version.
The changes introduced in CMMC 2.0 apply to both new and existing contractors. This updated framework aims to establish enhanced cybersecurity maturity and alignment with industry standards. Therefore, all organizations involved in DoD contracts must understand and comply with the updated CMMC 2.0 framework to maintain compliance and continue working with the DoD.
Learn more: What is CMMC Compliance? A Beginner’s Guide
When Will CMMC 2.0 be Released?
The Department of Defense (DoD) anticipates releasing CMMC 2.0 on or after October 1, 2026, as part of a phased plan that includes CMMC requirements for every level of compliance (1, 2, and 3) in all solicitations starting from that date. The DoD’s proposed rule for the Cybersecurity Maturity Model Certification (CMMC) Program confirms this date.
How Long Will It Take to Prepare for CMMC 2.0?
Preparing for a CMMC 2.0 assessment can be time-consuming. For Level 2 compliance, the most common level for defense contractors, the process can take anywhere from 12 to 18 months, including the preparation period and the waiting time for the assessment results.
Fortunately, defense contractors can streamline the process with these proactive compliance efforts:
- Address Your Cybersecurity Measures: Proactively addressing cybersecurity measures contributes to a more streamlined process as you work toward compliance.
- Mitigate Cybersecurity Risks: Acknowledging and mitigating cybersecurity risks ahead of time can also help streamline the assessment process.
What’s the Deadline for CMMC?
The Department of Defense (DoD) and the government are expected to provide companies with a timeline for demonstrating compliance after the release of CMMC 2.0. This timeline usually extends over several months, providing organizations with sufficient time to adapt and fulfill the new requirements before they become mandatory.
It’s in your best interest to start early on CMMC compliance for several reasons:
- Smooth Transition: Starting early allows companies to transition smoothly to the new CMMC requirements without rushing or facing last-minute challenges.
- Competitive Advantage: Proactively achieving compliance can provide a competitive advantage by demonstrating readiness and commitment to cybersecurity standards, potentially leading to more contract opportunities.
- Avoiding Penalties: Delaying implementation increases the risk of non-compliance, which can result in penalties, contract loss, and reputation damage.
The risks of delaying CMMC implementation include:
- Financial Costs: Non-compliance can lead to fines, legal fees, and loss of revenue from missed contract opportunities.
- Reputation Damage: Non-compliance can tarnish a company’s reputation, leading to a loss of trust among clients and partners.
- Competitive Disadvantage: Non-compliance may disqualify a company from bidding on government contracts or put them at a disadvantage compared to compliant competitors.
Learn more: CMMC vs. FedRAMP: What’s the Difference?
Get Ahead of CMMC 2.0 Requirements With 38North Security
Complying with CMMC can be challenging. 38North Security, recognized as an expert U.S. DoD security organization, can simplify the process. As a designated Registered Practitioner Organization (RPO) by the CMMC Cyber Accreditation Body, we can help you develop customized CMMC strategies to meet your specific operational needs.
Talk to one of our senior advisors today to learn how 38North Security can help your company prepare for CMMC 2.0 compliance.
