Category: Uncategorized

By: Diana Salazar

A Big Change Is Here

The Department of Defense has finalized the rule that makes the Cybersecurity Maturity Model Certification (CMMC) part of actual contracts. This rule was published on September 10, 2025, and takes effect November 10, 2025. What does that mean for you? Starting November 10, contracting officers can include CMMC requirements in new solicitations and awards. Over the next three years, this will become standard for most DoD contracts.

Here’s the good news: you still have time, and you can prepare without blowing your budget. We want to help you cross the CMMC compliance finish line and stay compliant. Keep reading to learn what’s changing, what you’ll see in RFPs, what steps you can take now to stay competitive, and how Securitybricks can help you.

What changed with 48 CFR?

Until now, CMMC was more of a policy than a contract requirement. That changes with the 48 CFR final rule. This rule adds CMMC language into the Defense Federal Acquisition Regulation Supplement (DFARS), which means it’s now enforceable in contracts.

Two key pieces of language make this happen:

• DFARS 252.204-‑7025 – This is the notice in the solicitation. It tells you what CMMC level you need to have to be eligible.
• DFARS 252.204-‑7021 – This is the contract clause. It says you must keep that CMMC level for the entire contract, including any extensions.

In plain English:

• You need to comply with the correct CMMC level before you can win government contracts.
• You need to maintain that level of compliance for as long as you’re on the contract.
• Your subcontractors need to meet the same standard for their part of the work.

What Levels Mean and What’s Required

Here’s a quick refresher:

Level 1: For contracts with Federal Contract Information (FCI). Requires an annual self-assessment.

Level 2: For contracts with Controlled Unclassified Information (CUI). Requires either a self-assessment or a third-party certification (C3PAO), depending on the program.

Level 3: For the most sensitive programs. Requires a DoD-led assessment.

What you’ll see in RFPs and Contracts

Here’s how these changes will show up in real life.

Section I: The Legal Stuff

This is where the DFARS clauses live. Expect to see language like:

“The Offeror shall have a current CMMC status for each information system proposed to be used in performance of this contract, at or above the level identified in the solicitation.” (DFARS 252.204-‑7025)

And:

“The Contractor shall maintain the CMMC level identified in this contract for the in-scope information system(s) throughout contract performance, including option periods.” (DFARS 252.2047-‑021)

Translation: You need the right CMMC level to win, and you need to maintain it throughout the life of the contract, including any extensions or renewal period.

Section L: What You’ll Need to Submit

Expect instructions like these:

• Tell us your CMMC level for each system you’ll use.
• Give us your official and unique DoD UID from SPRS (the government’s database).
• Share the date and score of your last self-assessment and who signed off on it.
• If Level 2 certification is required, provide the certification date and the name of your assessor (C3PAO).
• Explain how you’ll make sure your subcontractors meet the right level and how you’ll keep checking during the project.

Section M: How You’ll Be Evaluated

Think of this as a pass/fail check. The government will confirm your CMMC status before awarding the contract. They’ll check SPRS for self-assessments or the official CMMC database for Level 2 certifications. If you don’t meet the 110 security requirements from NIST SP 800-171, you won’t be in full compliance, and you won’t win the award.

Subcontractor Flow Down

If you’re the prime contractor, you’re responsible for your sub-contractors. You must:

• Verify their CMMC level before you sign them on.
• Keep records of that verification.
• Monitor their status during the contract.

Start With a Simple 30-60-90 Day Plan

You can’t do everything at once. Here’s a practical roadmap to follow:

Days 1–30: Get Clarity

1. Identify which contracts or bids will need CMMC and determine if they have CUI or FCI information.
2. Create a CUI boundary that will be used to assess your Level 2 controls.
3. Identify your FCI or CUI assets, as well as Security Protection Assets (SPA) and Contractor Risk Managed Assets (CRMA) to understand your data flow and determine scope.
4. Gather your current documentation (System Security Plan, policies, procedures and dataflow diagrams).

Days 31–60: Close Gaps

1. For Level 1: Make sure the 15 basic safeguards are in place and documented.
2. For Level 2: Complete NIST SP 800-171 requirements and evidence them.
3. Post your self-assessment score in SPRS and set up your annual affirmation process.

Days 61–90: Test it

1. Run a mock assessment to catch any gaps.
2. If you need a C3PAO, book them now as slots will fill up fast.
3. Put a process in place to check subcontractor compliance before award and during performance.

4 Common Pitfalls to Avoid

1. Over-scoping: Don’t pull your entire company into scope if you can isolate the systems that handle CUI.
2. Leaving  documentation for last: For Level 2, most of the work is in policies, procedures, and evidence. Build documentation as you implement it, not after.
3. Delaying your C3PAO booking: If you need a third-party assessment, schedule early.
4. Ignoring subs: If your subcontractor isn’t compliant, you’re not compliant.

This plan seems simple, but it is not. The reality is that it is a very time-consuming, highly detailed exercise that requires skill and knowledge. Where we find the biggest challenge with most of our customers is almost always in determining the scope of the CMMC assessment.

How Securitybricks can Simplify your CMMC Journey

CMMC compliance is complex and time-consuming, especially when you’re juggling spreadsheets, chasing down evidence, and trying to keep up with requirements. Securitybricks can take the weight off your shoulders and streamline your CMMC compliance.  We pair automation with human insight. Our deep knowledge of compliance enables us to understand the requirements and determine the scope of your CMMC assessment. We leverage automation to assess the gaps, find remediation and develop the evidence.

Our CMMC readiness services along with Securitybricks CMM Accelerator included in our enclave implementations works behind the scenes to:

• Design a CUI boundary
• Implement a CUI enclave using Microsoft GCCH cloud
• Provide CMMC Level 2 artifacts including SSP, policies and procedures
• Automatically Validate technical controls
• Continuously monitor your environment

Whether you’re adding new tools or updating your setup, the automation we add shows you exactly what needs attention to become compliant and remain compliant without guesswork and back-and-forth; all with a team that understands both the technical and audit sides of CMMC. With Securitybricks you’re not just getting software, or service, you’re getting a partner. Securitybricks is the only Azure-native solution in Marketplace that’s built specifically to automate and simplify the CMMC journey from start to finish.

Why This Matters

Starting November 10, 2025, CMMC will no longer be optional; it becomes part of the contracting process. But it won’t all happen overnight. The Department of Defense is implementing CMMC in three phases over three years. In the first phase, you will see self-assessments, then third-party certifications for Level 2, and finally Level 3 assessments for the most sensitive programs.

This phased approach gives you time to prepare, but don’t wait, as things change rapidly. Many solicitations will start including CMMC language right after the effective date, and primes will expect their subs to be ready. If you start now, you’ll avoid last-minute scrambles and position your company as a trusted, compliant partner.

Date	Milestone
Sept 10, 2025	Final Rule Published
Nov 10, 2025	Rule Effective – Phase 1 Begins (Self-Assessments)
2026	Level 2 C3PAO Certifications Appear in More Contracts
2027	Level 3 DoD-Led Assessments Begin
2028	Full Integration Across DoD Contracts

Book a 30-minute CMMC strategy session or request a live demo of the Securitybricks CMMC Accelerator to see compliance status and guided remediation in Azure cloud environments. Contact us now at: info@securitybricks.io

By Tiffany Griffin, Product Manager

Why CMMC 2.0 Compliance Is So Challenging

For organizations in the Defense Industrial Base (DIB), achieving Cybersecurity Maturity Model Certification (CMMC) 2.0 compliance is no longer optional — it’s a mandate. However, the path to certification is riddled with complexity. Manual compliance processes are time-consuming, error-prone, and often lack the clarity needed to satisfy auditors. Teams struggle with fragmented documentation, inconsistent workflows, and the sheer volume of control objectives (e.g., 53 for Level 1, 320 for Level 2).

The stakes are high. Without certification, contractors risk losing eligibility for Department of Defense (DoD) contracts. Yet, many organizations lack the tools, experience, or bandwidth to navigate this journey efficiently.

This is where the ServiceNow CMMC 2.0 Accelerator comes in.

What the ServiceNow Accelerator Brings to the Table

The ServiceNow CMMC 2.0 Accelerator isn’t just another tool. It’s a launchpad for audit readiness, purpose-built to empower defense organizations and their extended supply chains to:

• Reduce time and cost of compliance
• Ensure readiness for CMMC audits
• Centralize compliance data and workflows
• Scale across enterprise environments

Let’s unpack the key capabilities that make this solution a game-changer.

Core Features of the CMMC 2.0 Accelerator

1. Preloaded NIST 800-171 Controls

The accelerator comes with a comprehensive library of control objectives aligned with NIST 800-171. These are automatically pulled into your CMMC package based on Level 1 or Level 2 selection.

2. Automated Assessment Workflows

From questionnaire generation to evidence collection, the accelerator automates the entire assessment lifecycle. Controls are generated in a draft state where the assessment frequency can be configured to send out assessments or questionnaires on regular intervals based on the control requirement.

3. Real-Time Compliance Monitoring

Dashboards provide instant visibility into compliance status, assessment progress, and control effectiveness. This enables proactive risk management and continuous monitoring.

4. POA&M and SSP Management

Generate System Security Plans (SSPs) and manage Plans of Action & Milestones (POA&Ms) with control owner responses for all 320 CMMC objectives. The SSP report is downloadable as a PDF directly from the platform.

5. Authorization Boundary Automation

Define and manage your CMMC boundary with precision. The system automatically identifies assets based on the boundary filter created, allowing for easy inclusion or exclusion from the authorization scope.

6. Role-Based Access and Approval Workflows

The platform supports role-based workflows, including approvals from Authorizing Officials (typically CISOs) at three key stages:

1. Categorize
2. Select
3. Authorize

7. Continuous Monitoring

Once controls are implemented and authorized, they enter the Monitor phase. Assessments are sent out based on frequency settings, ensuring ongoing compliance.

How It Works: A Step-by-Step Breakdown

Step 1: Create CMMC Boundary

System owners or CAM admins define the scope of systems to be monitored. Filters help identify relevant assets, which can be added or removed from the boundary.

Step 2: Prepare Authorization Package

Roles and responsibilities are assigned. The Authorizing Official reviews and approves the package before moving to the next step.

Step 3: Categorize

Select CMMC Level 1 or Level 2. The system pulls in the corresponding control objectives. Approval is required before proceeding.

Step 4: Select Controls

Control objectives are reviewed and approved. These form the basis for assessments.

Step 5: Implement Controls

Controls are generated and moved to attest state. Stakeholders complete assessments to determine compliance status.

Step 6: Assess and Monitor

Assessment responses are captured, and based on the results, the compliance status is updated and tagged as compliant or not compliant.

Step 7: Authorize and Generate SSP

Once all controls are assessed, the package moves to the Authorize step. A customized SSP report is generated and downloaded.

The Impact on Businesses

Organizations using the CMMC 2.0 Accelerator report:

• Time Savings: Automated workflows reduce manual effort and increase efficiency.
• Improved Accuracy: Standardized assessments and evidence collection minimize errors.
• Audit Readiness: Built-in approval workflows and documentation ensure preparedness for C3PAO reviews.
• Scalability: The solution supports both Level 1 and Level 2 certifications, making it suitable for prime contractors and subcontractors alike.

Built by Specialists, Trusted by the Industry

With over 20 years of experience in cybersecurity advisory services, Securitybricks brings deep domain experience and a proven track record.

From Complexity to Clarity

CMMC 2.0 compliance doesn’t have to be a burden. With the ServiceNow CMMC 2.0 Accelerator, organizations can transform a complex, manual process into a streamlined, automated workflow. From boundary definition to SSP generation, every step is designed to reduce friction, improve accuracy, and accelerate outcomes.

Whether you’re a prime contractor preparing for Level 2 certification or a subcontractor navigating Level 1 requirements, this solution equips you with the tools to succeed.

Ready to explore? Visit the ServiceNow Marketplace or contact us for a demo.

#CMMC #Cybersecurity #ServiceNow #ComplianceAutomation #DefenseIndustrialBase #Securitybricks #GRC #IRM #CMMCAccelerator

By Meena Venkat, Product Manager, Security & Compliance Services

In today’s rapidly evolving cybersecurity landscape, organizations handling Controlled Unclassified Information (CUI) face a complex landscape of risks and regulatory hurdles.

Disconnected tools and inconsistent configurations across multiple environments make it difficult to enforce unified security policies. Manual processes for compliance tracking and reporting are not only error-prone but also resource-intensive. To meet and maintain compliance, organizations must produce extensive documentation with regards to their current security posture.

In order to address these challenges, many organizations are now turning to Greenfield environments.

A Greenfield environment is a secure, isolated IT environment purpose-built to meet compliance and security requirements from the ground up, enabling easier alignment with modern compliance frameworks and a proactive security posture.

A Shifting Landscape: Rising Compliance and Security Demands

According to the official website of the United States Government, under the Department of Defense’s CMMC 2.0 framework, contractors must not only demonstrate initial compliance but also sustained cybersecurity maturity throughout the contract lifecycle.

This includes producing and maintaining extensive documentation such as System Security Plans (SSPs), Plans of Action and Milestones (POA&Ms), and evidence of control implementation across 110 security controls and 320 objectives. To add, these artifacts must align with NIST SP 800-171 standards and must be validated through either self-assessments or third-party audits, depending on the contract’s required maturity level.

Contractors must also post their assessment scores to the Supplier Performance Risk System (SPRS) and ensure that their CMMC certificate remains current and valid for the duration of the contract, as outlined by the DoD’s official CMMC Program Overview and CMMC 2.0 Proposed Rule.

Understanding Greenfield

In this context, a “Greenfield” is a logically and/or physically separated hardened environment used to isolate sensitive workloads.

A Greenfield environment, also known as a GCCH CUI Enclave, refers to a secure, isolated IT environment within Microsoft’s cloud platform, built to properly process, store, and transmit CUI. For example, the net new Microsoft 365 Government Community Cloud High environment is considered a Greenfield or GCCH CUI Enclave.

Greenfield environments are not just a technical solution. They represent a strategic shift toward proactive security architecture.

Greenfield environments are able to:

• Rapidly onboard new users, clients or projects with sensitive data requirements
• Demonstrate compliance maturity during audits
• Reduce long-term operational risk and technical debt

Industry Adoption

The Cybersecurity and Infrastructure Security Agency (CISA) has adopted a Greenfield strategy to modernize federal IT systems and proactively reduce cyber risks. This approach allows agencies to:

• Eliminate legacy vulnerabilities
• Implement Zero Trust frameworks
• Reduce attack surfaces
• Improve agility and security posture

How Greenfield Environments Address Current Challenges

Security by Design

Greenfield environments are built from the ground up with hardened configurations. Over 1,700 hardening configurations are applied to Microsoft 365 GCC High tenants to ensure a secure baseline. This isolation of sensitive workloads reduces lateral movement and attack surface.

Automated Compliance

A Greenfield environment integrates tools like Microsoft Purview Compliance Manager, Sentinel, and Defender for Endpoint to automate monitoring, alerting, and remediation. Mapped controls and documentation templates help streamline CMMC Level 2 compliance.

Zero Trust Enablement

Greenfield environments support Zero Trust principles by enforcing the least privilege access, micro-segmentation, and continuous verification, aligning with modern Zero Trust framework. This process effectively eliminates legacy vulnerabilities by starting fresh, therefore reducing the attack surface. 

Operational Efficiency

Greenfield environments offer a more economical and scalable alternative to retrofitting legacy systems, reducing manual work through automated gap assessments and built-in remediation guidelines. Organizations can scale securely without inheriting legacy vulnerabilities or technical debt.

Get Started with Securitybricks Today

Most defense contractors require CMMC Level 2 certification, which necessitates using Microsoft GCC High to meet compliance standards. Protecting CUI and Federal Contract Information (FCI) is critical.

Securitybricks can help you build, implement, and maintain a Greenfield environment to navigate CMMC compliance requirements efficiently and cost-effectively.

Greenfield – CUI Enclave Implementation

To enhance your cybersecurity posture, a new Greenfield or GCCH CUI Enclave is provisioned and configured. Our full range of services can help your organization build and implement a secure tenant configuration within M365 so that CUI is protected and proper controls are implemented to ensure CMMC Level 2 compliance.

Greenfield – CMMC Level 2 Artifact Development

Comprehensive documentation of the supporting policies and procedures required to achieve CMMC Level 2 compliance can be used to guide the operation of your new environment. This documentation includes your SSP, POA&M, risk assessments, and other essential policies and procedures.

Greenfield – License Procurement

As a trusted Microsoft Government security partner, the Securitybricks team has extensive experience navigating compliance and licensing for private and public sector organizations. We welcome the opportunity to collaborate with you to seamlessly provide the necessary Government Community Cloud (GCC High) licenses, ensuring your organization has secure, compliant access within the Microsoft ecosystem.

Ready to take the complexity out of CMMC compliance? Contact us to schedule a personalized demo or consultation.

By Diana Salazar, Segment Growth Leader, Securitybricks and Risk Services

As the Cybersecurity Maturity Model Certification (CMMC) 2.0 framework becomes an established requirement across the defense industrial base (DIB), organizations of all sizes are focused on achieving their initial certification. While obtaining CMMC compliance is a critical milestone, it is just the first step, because true security and compliance are continuous journeys. Continuous compliance is crucial for IT leaders and security professionals to manage risk and maintain contract eligibility in a changing environment. But what does it all mean to your organization? Let’s explore the subject further.

What Continuous Monitoring Means for CMMC Compliance 

While human insight is essential for compliance, the process should not be entirely manual and prone to errors. Continuous monitoring goes beyond point-in-time audits and endless spreadsheets by providing real-time visibility into 110 security controls and 320 objectives within your compliance posture.

Under CMMC 2.0, the focus expands from achieving certification “one time” to embedding continuous compliance practices into everyday operations. Contractors are expected not only to meet the required security controls at the point of certification, but to demonstrate ongoing adherence and effective risk management throughout the contract lifecycle.

This means implementing systems and processes capable of: 

• Monitoring cybersecurity controls in real time
• Detecting and responding to security incidents promptly
• Performing regular internal assessments and updates aligned with evolving threats and compliance requirements
• Validating compliance with new system implementations
• Maintaining comprehensive documentation and audit trails for transparency and accountability

The Challenge with Compliance and Monitoring CMMC Compliance

Survey results in a recent Federal News Network article revealed that cost is the primary challenge in implementing CMMC. This suggests that organizations may not be considering continuous monitoring beyond the initial certification, which is crucial for staying contract-ready. Furthermore, a Department of Defense cybersecurity leader recently stated: “CMMC is not a one-time event; it’s a continuous journey. The ability to maintain compliance consistently—through monitoring, auditing, and rapid remediation—is key to securing the defense supply chain” (DoD Cybersecurity Directorate, 2025).

Why Harness Automation to Simplify Compliance Efforts?

Automated compliance solutions enable organizations to continuously scan gaps related to access controls, configuration standards, data encryption, and incident documentation, all critical to CMMC requirements. By generating audit-ready reports with minimal manual effort, these solutions help your team stay focused on what matters: reducing risk and maintaining operational agility. For instance, a simple implementation of new software or systems can disrupt your compliance if not properly managed. Securitybricks’ cloud-native, scalable solutions empower small and medium-sized businesses, as well as enterprises to achieve continuous compliance without expensive integration projects or specialist overhead.

Building Confidence for the Next Audit

Continuous compliance generates a clear, up-to-date compliance trail simplifying official third-party CMMC assessments and accelerating remediation cycles. Real-time monitoring and documentation reduces surprises during audits, builds trust with government partners, and helps future-proof organizations against evolving cybersecurity demands.                    

Make Continuous Compliance Your Security Advantage

Sustaining CMMC compliance in today’s rapidly changing cybersecurity landscape requires more than achieving certification. It demands ongoing, automated compliance monitoring that integrates seamlessly into your operations, allowing you to reduce risk, maintain contract eligibility, and focus on growing your business.

SecurityBricks is dedicated to simplifying compliance for the DIB. Let us help you transform compliance from a risk into a competitive advantage so your security and success can go hand in hand.

Get Started with Securitybricks Today

Ready to take the complexity out of CMMC compliance monitoring? Contact us to schedule a personalized demo or consultation. Discover how our automated compliance-as-code platform empowers you to maintain continuous CMMC compliance while improving security posture and freeing your team to focus on strategic priorities.

Author: Ashley Lex 

In our previous LinkedIn Pulse post, we emphasized that defining your CUI boundary is the most important first step toward CMMC Level 2 readiness. In this article, we’re zooming in on what that means specifically within Microsoft Azure Government (GCC or GCC High) environments. Azure Government is a FedRAMP approved platform used by many federal contractors, often with the assumption that FedRAMP alone guarantees CMMC compliance.

Azure Government ≠ Automatic Compliance

Azure Government, GCC, and GCC High are all FedRAMP authorized environments. This means they are approved to store, process, and transmit Controlled Unclassified Information (CUI). However, FedRAMP authorization doesn’t automatically make your organization CMMC compliant.

CMMC is about your implementation of security controls, not just the platform’s capabilities. It’s your responsibility to define the boundary, configure the environment securely, and provide evidence to a C3PAO that all 320 Level 2 control objectives are met.

Let’s break down what CMMC readiness looks like in the Microsoft Government cloud.

Step 1: Get Qualified for Azure Government

Before you can use Microsoft’s Government services, contractors must verify their eligibility via the online Azure Government Onboarding Form.

You’ll need to provide details like your Commercial and Government Entity (CAGE) code to determine eligibility. Once approved, you can procure licenses through a Microsoft Government-authorized reseller.

It’s important to understand what Microsoft services you’ll need, whether it’s:

• Microsoft 365 GCC/GCC High (i.e., for email, Teams, SharePoint)
• or Azure Government (i.e., for hosting VMs, databases, and web applications)

Step 2: Implement the Right Controls — and Know Who Owns What

Once you’re operating in a government cloud environment, the next step is to implement the CMMC Level 2 controls. Microsoft provides a strong baseline of security capabilities but remember: Compliance is a shared responsibility.

Review the Microsoft Shared Responsibility Matrix to understand:

• Which controls are owned by Microsoft (e.g., physical security of data centers)
• Which controls are shared (e.g., patch management, logging)
• Which controls are your responsibility (e.g., access control policies, incident response plans)

This matrix is available upon request from Microsoft and is something your C3PAO will expect to see during the assessment.

Step 3: Leverage Automation to Validate and Monitor Compliance

Once you’ve implemented the required security services (e.g., endpoint protection, threat detection, log analysis), it’s time to validate that they meet CMMC Level 2 requirements.

Using a tool like the Securitybricks CMMC Accelerator to scan your Azure GCC or GCC High environment will instantly validate your control implementation. This accelerator will cut the guess work out of your compliance, significantly reduce manual effort involved in continuous monitoring, and give your team real-time visibility into your CMMC compliance status.

Other key features include:

• Automated technical control checks for Azure workloads
• Over 700 checks mapped to the 320 CMMC Level 2 objectives for M365
• Evidence collection built into the instance
• Remediation guidance for failed controls
• Dashboards to visualize compliance posture
• Built-in SPRS scoring to prioritize non-POA&M-eligible controls

Using Azure Government is a great first step, but it’s just the beginning. For CMMC Level 2 compliance, you’ll also need to document:

• Which Azure subscriptions, resource groups, or workloads are in scope.
• Which assets store, transmit, or process CUI.
• How access is managed (e.g., users, service principals, external identities).
• How boundary controls are implemented (e.g., firewalls, NSGs, Azure Policy).
• Which third-party services or APIs are integrated, and whether they’re also compliant.

Conclusion

CMMC compliance starts with boundary clarity. It is absolutely achievable—but only when you’re intentional about your architecture, documentation, and tooling. Azure Government can support your CMMC journey, but it’s not a “plug and play” solution. Your boundary must be clearly defined, documented, and defended with evidence aligned to the 320 control objectives.

As cyber threats continue to evolve at a rapid pace, the Cybersecurity Maturity Model Certification (CMMC) framework has become a cornerstone of the defense supply chain. CMMC mandates the implementation of stringent cybersecurity protocols for government contractors, with the primary aim of safeguarding sensitive Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). While CMMC compliance is indispensable for Department of Defense (DoD) contractors, its impact is well on its way beyond the defense sectors.

We can anticipate the underlying principles of CMMC to permeate other industries, such as technology and finance, as these sectors recognize the potential impact of cybersecurity breaches that are exacerbated by the integration of advanced technologies such as artificial intelligence (AI). Consequently, the adoption of third-party audits and rigorous cybersecurity measures are likely to become industry standard for every link in the supply chain, a shift that represents a broader trend towards enhancing the resilience of critical business functions against cyber threats and the need for more comprehensive risk management strategies.

Key CMMC 2.0 Updates

Simplified Three-Tiered Model

CMMC 2.0 has a three-tiered certification model; however, this doesn’t necessarily make it easier for organizations to achieve compliance. This tiered model stipulates that organizations handling CUI and FCI must adopt cybersecurity best practices at incrementally advanced levels; most organizations will need Level 2 compliance, while Level 1 and Level 3 are less likely to occur. To that end, CMMC 2.0 enables contractors to clearly determine their current level within the certification process and identify specific actions necessary to align with DoD cybersecurity standards. Furthermore, it empowers organizations to tailor their security efforts according to their specific contracting obligations, leading to more efficient resource allocation.

Enhanced Assessment Requirements

CMMC 2.0 introduces a more flexible, risk-based approach to assessments, emphasizing the importance of aligning cybersecurity efforts with the specific risk profiles of different defense programs. This allows companies to allocate their resources more effectively, focusing on areas that require the most attention and reducing unnecessary costs. The new framework prioritizes critical defense programs, ensuring that the most sensitive projects receive the highest level of scrutiny, while offering more cost-effective options for companies working on less sensitive contracts.

Increased Flexibility with POA&Ms

Plans of Action and Milestones (POA&Ms) offer organizations a strategic avenue to address certain cybersecurity shortcomings in a structured manner while working towards achieving CMMC compliance. The introduction of POA&Ms also gives businesses more leeway to rectify non-compliance issues without immediately jeopardizing their certification status. A mechanism that affords companies the opportunity to outline specific steps and timelines for resolving identified gaps.

This doesn’t come without any caveat. It’s worth noting that not everything can be inserted in a POA&M if you want to obtain certification. The inclusions should be lower-weight requirements in order to score high enough to pass. Additionally, POA&Ms must be remediated within 180 days of the assessment date.

While POA&Ms provide a cushion for managing compliance, they should be integrated into a broader, more proactive cybersecurity strategy, and organizations must still prioritize meeting high-priority requirements.

Phased Implementation

The new requirements will be phased into DoD contracts over a three-year period, starting in 2025. This gradual introduction will allow some organizations additional time to understand and integrate the necessary changes into their operational procedures.

During this phase-in period, and particularly for contracts that are yet to have this requirement, companies are encouraged to prioritize adopting cybersecurity measures that align with the updated standards, ensuring they meet the deadline without compromising their operations. Moreover, the phased approach provides an opportunity for businesses to conduct thorough assessments of their existing cybersecurity frameworks, identifying potential gaps and addressing them prior to required compliance.

Impact on Contractors

Flow-down to Subcontractors

Prime contractors are tasked with extending CMMC requirements to their subcontractors, ensuring a comprehensive flow-down of compliance obligations throughout the entire supply chain. This aspect of the CMMC framework mirrors existing clause requirements in many federal contracts, underlining the critical nature of consistent cybersecurity practices across all tiers of the defense supply chain. Therefore, prime contractors are tasked with the responsibility of verifying and ensuring that their suppliers adhere to the same stringent standards mandated by CMMC 2.0. This verification process not only involves rigorous auditing trails but also ongoing engagement with subcontractors to address any compliance issues that arise.

Engage Your MSP

Managed Service Providers (MSPs) are important allies for defense contractors navigating CMMC compliance. Although MSPs themselves may not require certification, their role as External Service Providers (ESPs) carries significant weight in ensuring cybersecurity standards. Therefore, MSPs should still undergo assessment to ensure that they can meet the minimum security requirements. The assessment can be done by the organization independently as well.

This step is essential because it helps guarantee that all aspects of cybersecurity are thoroughly reviewed, leading to stronger defense against potential threats. Moreover, engaging MSPs effectively allows contractors to leverage external expertise, thereby optimizing resources and reinforcing compliance throughout their operations.

Commitment to Continuous Compliance

CMMC 2.0 places a strong emphasis on continuous compliance, underscoring the principle that cybersecurity should be a sustained focus rather than a periodic certification endeavor. Organizations are encouraged to integrate cybersecurity into their regular operations and maintain vigilance even outside of formal review periods. This shift reflects the DoD’s expectation that cybersecurity must be ingrained in every aspect of a contractor’s operations, ensuring ongoing protection of sensitive data. Businesses must adopt a proactive approach, conducting regular audits and assessments that help identify potential vulnerabilities before they can be exploited.

Impact of Non-Compliance with CMMC 2.0

The False Claims Act (FCA) enforces CMMC compliance, serving as a powerful regulatory mechanism. Non-compliance is a grave risk for businesses as it can lead to lawsuits, contract losses, and hefty financial penalties that may severely impact an organization’s financial stability. In addition to these repercussions, there is the potential risk that individuals within the organization, or even competitors, can leverage the FCA to sue on behalf of the government. In short, whistleblowing.

The stakes for failing to meet CMMC 2.0 requirements are incredibly high. This is especially pertinent for companies relying heavily on defense contracts, where maintaining compliance is synonymous with protecting their market position and reputation. Hence, proactively addressing compliance gaps not only mitigates legal and financial risks but also safeguards your organization’s integrity.

Conclusion

With the introduction of CMMC 2.0, organizations now have a more structured pathway to achieving compliance, which is paramount for the protection of sensitive information within the defense supply chain. The phased rollout from 2025 to 2028 affords businesses the time to align their cybersecurity frameworks with the latest requirements. However, this should motivate companies to act swiftly rather than complacently.

Proactive measures are critical as delaying these can lead to unforeseen complications amidst increasing cybersecurity threats and more stringent enforcement. Furthermore, early compliance not only helps ensure eligibility for future DoD contracts but also offers a significant competitive advantage by preempting last-minute disruptions. For smaller enterprises, it’s important to prioritize investments in training and cybersecurity enhancements to effectively bridge any compliance gaps before implementation deadlines loom.

Need help navigating CMMC compliance? Securitybricks is one of a select few firms holding both FedRAMP 3PAO and CMMC C3PAO accreditations. We offer a phased approach tailored to your security and compliance needs, ensuring you have the right information and tools for long-term success. Securitybricks is part of Aprio, a premier business advisory and CPA firm.We help you navigate the complexities of CMMC compliance with confidence. Get in touch today.

Understanding the importance of the Cybersecurity Maturity Model Certification (CMMC) is essential for organizations who aim to secure contracts with the U.S. Department of Defense (DOD). As cybersecurity threats grow more sophisticated, so does the need for cutting-edge tools to demonstrate an organizations adherence to CMMC standards.

While CMMC serves as a benchmark in cybersecurity compliance, integrating innovative tools can help businesses gain real-time insights and improved controls over their cybersecurity frameworks to swiftly identify and address vulnerabilities. Leveraging advanced technology, such as artificial intelligence and machine learning solutions that are FedRAMP compliant and/or meet CMMC requirements, can facilitate compliance by automating, streamlining, and enhancing various aspects on the journey to CMMC compliance. In today’s rapidly evolving technological landscape, CMMC compliance is an integral piece to ensure an organization can maintain the trust of their clients and partners by protecting their assets.

Understanding CMMC Compliance and the Framework

What is the Cybersecurity Maturity Model Certification?
 

Developed by the DOD, CMMC aims to strengthen cybersecurity within the Defense Industrial Base (DIB) by enforcing a standard that ensures contractors protect sensitive DOD information. Since compliance with CMMC is mandatory for businesses hoping to secure or retain government contracts, federal contractors who have their own cybersecurity measures already in place must ensure their programs are good enough to meet the rigorous CMMC requirements.They must adhere to the CMMC standards before they can bid and win future government contracts.

This new federal law will have ripple effects throughout the entire economy as contractors, subcontractors, and technology providers that handle Controlled Unclassified Information (CUI) will be held to these standards.

Differences Between CMMC and NIST

Understanding the differences between CMMC and NIST can be confusing because their objectives in enhancing cybersecurity can overlap. The main difference is that NIST 800-171 is a standard set forth by the National Institute of Standards and Technology and CMMC is the mandate to comply with NIST 800-171 to protect systems that store, transmit or process CUI.

However, when it comes to working with DOD contracts and CUI-related data, there is no one or the other.

Essential Tools for CMMC Compliance

Email and File Sharing Protection for CUI

The protection of CUI during email and file sharing is not only critical in today’s evolving digital landscape but also to achieve CMMC compliance. To effectively safeguard CUI, businesses must implement robust solutions such as the adoption of advanced encryption technologies to strengthen email communications and secure file-sharing platforms that allow authorized users access to manage CUI data efficiently. Employing end-to-end encryption and multi-factor authentication tools can enhance an organization’s security framework through a dual layer of protection and regularly updating security protocols and training employees on best practice in handling CUI can streamline the process to ensure compliance with CMMC standards.

Endpoint Protection

Designed to detect, prevent, and respond to malware and cyber attacks, endpoint protection tools work together seamlessly to isolate compromised devices and neutralize potential threats before they can get the chance to spread further into an organization’s systems. Endpoint protection is more than a defensive cybersecurity measure; it is a strategic element that enhances the overall cybersecurity resilience of a business and facilitates compliance. A robust endpoint protection strategy consists of behavioral analysis, machine learning algorithms, and real-time threat intelligence to safeguard infrastructure integrity and alignment with the CMMC framework.

The Role of SIEM

Security Information and Event Management (SIEM) solutions offer a centralized method to collect, monitor, and analyze security events across an entire organization. Serving as a pivotal role in advancing CMMC compliance, SIEM systems are designed to collect logs and data from across network devices to detect suspicious activity and unauthorized access attempts and respond to cyber threats in real-time. Leveraging SIEM technology can not only strengthen a company’s cyber defense posture but also provide comprehensive visibility into network devices, servers, and applications to establish a baseline of “normal” network activity.

GRC Solutions for Continuous Monitoring

Governance, Risk, and Compliance (GRC) tools provide a comprehensive framework that supports the management of security compliance risks as well as enhances the ability to track regulatory changes and policy updates. To combat evolving cybersecurity threats, a robust GRC platform is vital to maintaining CMMC compliance and can facilitate automated data collection and reporting, streamlining the audit process and reducing administrative burden. Effective GRC solutions can help businesses minimize compliance gaps and foster a more collaborative approach to cybersecurity readiness. 

Security Awareness and Training

Human error is one of the leading causes in cybersecurity breaches and non-compliance incidents. So, it’s not a surprise that employees are often considered the weakest link when it comes to cybersecurity. Therefore, creating a culture of ongoing education and training programs around security awareness is integral to ensuring employees are well-equipped in the face of potential threats and are encouraged to report suspicious activity. An organization’s security awareness and training programs should encompass hands-on training on a wide range of topics, including phishing scams, password management, and secure communications. Since cyber threats evolve daily, staying ahead is important and training sessions must be regularly updated and aligned with current cybersecurity best practices. 

Maintaining CMMC Certification

Continuous monitoring and adapting to evolving cybersecurity threats is the key driver in maintaining CMMC certification. To effectively demonstrate ongoing CMMC compliance with DOD standards, businesses must be proactive and regularly review their cybersecurity strategies to ensure they can meet any new requirements or make any necessary modifications in their CMMC compliance. Planning for CMMC assessments and audits requires a thoughtful and comprehensive approach aimed at identifying any gaps in an organization’s current cybersecurity practices and ensuing the appropriate tools, technology, and people are in position to support these compliance efforts.

Conclusion

Cutting-edge cybersecurity tools and technology play a curial role in achieving and maintaining the rigorous CMMC compliance standards set by the DOD. Through strategic implementation of cybersecurity tools, such as endpoint protection, GRC, and SIEM, organizations can safeguard their operations by detecting and responding to potential threats in real-time, thus upholding their CMMC compliance with greater resilience.

Need help navigating CMMC compliance? Securitybricks is one of the few U.S. firms holding both FedRAMP 3PAO and CMMC C3PAO Accreditations. We offer a phased approach tailored to your security and compliance needs, ensuring you have the right information and tools for long-term success. Securitybricks is part of Aprio, a premier business advisory and CPA firm. 

Connect with our team today.  

It should come as no surprise that the deadline for complying with the Cybersecurity Maturity Model Certification (CMMC) is fast approaching. The CMMC framework, a cornerstone in upholding rigorous cybersecurity standards, consists of a tiered framework from basic cyber hygiene at Level 1, maturing to highly sophisticated cybersecurity practices and processes at Level 5, such as NIST SP 800-171 guidelines.

While organizations in a variety of sectors must systematically complete each level and implement the appropriate controls, CMMC compliance also involves routine audits and assessments to demonstrate an organization’s commitment to safeguarding heightened security standards.

Common CMMC Compliance Challenges

While common CMMC compliance challenges vary from understanding the complex requirements to aligning existing processes with new standards, there are three main compliance challenges companies will face as they work to achieve their CMMC certification:

1. Navigating the CMMC framework presents a significant challenge as it is designed to merge various cybersecurity standards and best practices, promoting a comprehensive approach to data protection. However, the complexity of understanding and implementing these standards also requires significant resources and robust planning to help ensure all necessary safeguards are correctly in place. To effectively advance through the CMMC levels, companies must fully understand the stipulations that come with the framework, such as the numerous control families that must be deployed progressively.

2. Protecting Controlled Unclassified Information (CUI) remains a pivotal concern for companies, especially those working with the Department of Defense (DOD), given the sensitive nature of that data. The CMMC framework is built on stringent measures to safeguard CUI from unauthorized access, while also ensuring its integrity throughout business operations. But safeguarding CUI is not straightforward, as it involves understanding complex regulatory requirements that are integral to CMMC compliance. An essential part to achieving this standard is developing comprehensive data protection policies and utilizing advanced technological solutions, such as encryption and access controls to maintain compliance mandates and boost resilience against cyber threats.

3. Addressing the cost of compliance is an essential step for companies striving to meet CMMC requirements. The implementation of the CMMC framework can be a costly endeavor, from investments in new software and training expenses to enhance workforce skills to the costs of operational downtime as businesses adjust their processes to incorporate new security protocols. Strategic financial planning is important for companies to allocate costs effectively and explore potential financial assistance or incentives that might be available to balance operational needs with compliance obligations.

Understanding the CMMC Compliance Process

A comprehensive understanding of each level’s expectations is crucial for ensuring implementation and achieving compliance. Each CMMC level embodies different criteria and enhanced cybersecurity practices, starting at Level 1, which is foundational for all organizations in any industry. As companies progress through Levels 2 to 5, they are required to adopt increasingly complex cybersecurity measures that address specific control families based largely on NIST SP 800-171 standards.

To adhere to the CMMC compliance process, companies must:

• Perform a rigorous assessment of their current security posture relative to CMMC standards to identify existing gaps and implement any necessary enhancements.
• Develop a detailed action plan tailored to address any deficiencies and align their security posture with regulatory mandates.
• Review and update controls continuously to ensure sustained compliance and protection of sensitive information.

Preparing for the CMMC Compliance Deadline

Aligning organizational strategies with the rigorous demands of the CMMC framework is a step towards securing current operational resilience. To seamlessly transition and meet the CMMC deadline, companies must thoroughly analyze the modifications in the CMMC framework, focusing on changes in control specifications and reporting requirements, conduct an extensive gap analysis to ensure that all personnel are well-equipped to address any new criteria, and ensure that current cybersecurity infrastructure aligns with the updated standards.

Taking a proactive approach can mitigate potential operational disruptions and help organizations stay on track to meet the CMMC compliance deadline.

The Role of a Third-Party Assessment Organization

Engaging with certified Third-Party Assessment Organizations (C3PAOs) can play a pivotal role in helping organizations navigate the complexities of CMMC compliance. From providing critical insights and tailored guidance throughout the compliance journey to ensuring all security controls are correctly implemented. C3PAOs can help organizations streamline the path to achieving CMMC compliance and bolster their readiness to meet changing cybersecurity protocols.

The Future of CMMC Compliance

While the cybersecurity landscape will continue to evolve, so will the requirements associated with CMMC. To effectively address emerging threats and vulnerabilities, organizations must accept that compliance is not a static endpoint, but a dynamic process. Adopting new technological advancements in cybersecurity practices and remaining agile will be key for companies to continuously maintain CMMC compliance.

This involves not only keeping pace with the latest advancements in cybersecurity technologies, such as artificial intelligence, machine learning, and predictive analytics, but also anticipating how these technologies can be leveraged to address an increasingly complex threat environment.

Additionally, its crucial for companies to invest in their people through education and training to ensure they are proficient at deploying cybersecurity best practices and can effectively address any potential threats. Fostering an organizational culture of continuous learning and innovation, not only enhances an organizations cybersecurity resilience but positions them to face future challenges with confidence.   

Conclusion

To achieve CMMC compliances, companies must embrace an adaptive and proactive approach that ensures they are consistently meeting evolving cybersecurity standards, promoting a culture of ongoing learning to stay informed on the latest regulatory changes, and regularly reassess their cybersecurity strategies by integrating advanced technologies to enhance their protection capabilities.

Got CMMC compliance pains? Securitybricks is one of the few U.S. firms holding both FedRAMP 3PAO and CMMC C3PAO Accreditations. We offer a phased approach tailored to your security and compliance needs, ensuring you have the right information and tools for long-term success. Securitybricks is part of Aprio, a premier business advisory and CPA firm.

Need help navigating CMMC compliance? Connect with our team today.