If you’re a defense contractor, you must have received a memorandum asking you to comply with the new CMMC framework.  

For the uninitiated, CMMC (short for the Cybersecurity Maturity Model Certification) is a certification model that assesses the extent to which defense contractors adhere to specified cybersecurity regulations. The program was developed by the United States Department of Defense (DoD) and has undergone major reforms over the years. Its latest iteration was published on October 15, 2024, and took effect two months later.  

With the new CMMC framework, the DoD seeks to verify that its contractors implement proper security measures required to safeguard Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).  

However, while the new CMMC framework took effect in December 2024, the program will undergo a phased roll-out.  

The phased implementation allows Defense Industrial Base (DIB) companies to take a systematic approach to attaining certification. Besides, it enables vendors to predict future developments in CMMC compliance requirements.  

To help you keep up with CMMC’s evolution, we’ve rounded up key trends likely to shape the program’s future.  

Retracing the Footsteps: The Origin and Significance of CMMC 

While CMMC has made significant impressions more recently, its history dates back to 2010.  

On November 4, 2010, President Obama signed Executive Order (E.O.) 13556 to streamline how the Executive Branch handles federal information requiring extra protection. The order stipulated that all controlled unclassified information be managed, stored, and disseminated consistently with existing laws and best practices.  

However, it was not until September 2020 that CMMC 1.0 was unveiled. The program featured cybersecurity practices grouped into five distinct categories known as Levels.  

Level 1 required defense vendors to ensure basic cyber hygiene within their systems, focusing on common cybersecurity practices like installing anti-virus software. Level 5, CMMC 1.0’s most advanced maturity category, addressed ongoing threats to the defense industrial base.  

Unfortunately, CMMC 1.0 had significant loopholes that hackers could exploit to wage aggressive cyber campaigns against the defense supply chain. Mounting DoD-targeted attacks, such as the SolarWinds attack, exposed glaring vulnerabilities in critical defense infrastructures. It was time to upgrade the program.  

The DoD embarked on a raft of modifications to CMMC 1.0, which eventually culminated in CMMC 2.0, released on October 15, 2024.  

The unveiling of CMMC 2.0 underscores the DoD’s commitment to combating constantly evolving cyber threats. It urges vendors to maintain high vigilance by actively monitoring their systems for unprecedented attacks. 

What Does The Future Hold For CMMC? 

While CMMC 2.0 represents the cutting edge of cybersecurity protection, it’s not static. As we move into the future, we will likely see the program revamped in line with evolving cybersecurity threats. Below are some expected CMMC reforms and trends;

1. Shift from Self-Reported Compliance

Both CMMC 1.0 and 2.0 are largely based on the security standards defined in the National Institute of Standards and Technology (NIST) 800-171. The core difference is that CMMC 1.0 emphasizes self-affirmation while CMMC 2.0 implements a hybrid model where vendors can self-audit or request external assistance, depending on the desired certification level.  

CMMC 2.0 has three certification levels, down from five in its previous iteration. Level 1 requires self-reporting, while for Levels 2 and 3, an external assessor must conduct relevant CMMC audits.  

The shift from self-assessment to independent reviews is a trend that’s likely to continue. While self-reporting partially places the burden of accountability on defense contractors, independent audits will foster standardization in CMMC assessment and uphold the program’s integrity. 

2. Incorporation of Automation

Higher CMMC 2.0 maturity levels have already implemented sophisticated threat detection techniques like threat hunting. However, we might see the integration of advanced automation technologies like artificial intelligence (AI).  

AI and machine learning (ML) utilize deep learning algorithms to detect threats that would easily escape conventional cyber monitoring techniques. They perform extensive background scans for anomalous patterns and signal responsible cyber teams, enabling swift, preventive action.  

Note that the DoD has already invested significantly in AI to improve workforce management. Therefore, it may not be long before AI finds its way into CMMC procedures.  

3. Insistence on Ongoing Threat Monitoring

The whole idea of upgrading CMMC 1.0 was to respond to emerging cybersecurity threats along the defense supply chain. However, because cybercriminals are getting craftier by the day, the current framework is expected to be revamped even further.  

Presently, organizations that need Level 1 CMMC compliance must conduct annual self-affirmation, while Levels 2 and 3 certifications call for triennial assessments. The DoD may encourage extra vigilance by shortening these frequencies, allowing its vendors to stay on top of cybersecurity.  

Besides, the objective of periodic assessments will shift from merely “checking the boxes” to actively scoping for dynamic threats.

4. Focus On Small Businesses

Small businesses enjoyed considerable freedom in CMMC 1.0, which was largely pegged on self-assessment.  

CMMC 2.0 has since altered the dynamics by requiring all businesses that handle DoD-designated sensitive data to comply with the CMMC regulations application at their certification level.  

Cybercriminals have realized that it’s far easier to breach unsuspecting, small-time defense suppliers than wage a campaign directly on the DoD’s critical infrastructures. To seal these gaps, the agency might broaden the aperture further, obligating companies that do business with it at all levels to achieve CMMC certification. 

5. Widespread Adoption by Other Federal Agencies

CMMC may be a DoD initiative. However, other federal agencies will equally deploy the program to ward off cybersecurity threats.  

Presently, plans are in motion to incorporate CMMC compliance requirements into all contracts by 2026. This move will undoubtedly stimulate more interest in the cybersecurity model by other state organs.  

The fact that many recent cyber-attacks targeting the United States were aimed at multiple state organs indiscriminately will only fuel CMMC adoption. By obligating their suppliers to align with CMMC requirements, federal agencies will seek to streamline cybersecurity operations both at interdepartmental levels and with their external stakeholders.  

6. Increased Synergy Between CMMC And FedRAMP

As CMMC’s sphere of influence extends into other federal agencies, we’re likely to see a closer interplay between the program and FedRAMP (Federal Risk and Authorization Management Program).  

FedRAMP is a federal program that standardizes practices for vetting cloud service providers (CSPs). Unlike CMMC, which is still essentially a DoD program, FedRAMP is applicable across all state organs. The program authorizes its assessors, known as Third-Party Assessment Organizations (3PAO).  

When CMMC eventually pervades other state organs, federal contractors will be able to tap into the experience of 3PAOs and C3PAOs to enhance the quality of their cybersecurity audits.  

Note that many current defense contractors partner closely with CSPs, especially while outsourcing IT services. Vendors seeking CMMC certification services under Level 2 or above must only collaborate with CSPs who have attained a FedRAMP Moderate ATO or its equivalence. Therefore, merging CMMC with FedRAMP to bolster cybersecurity across federal supply chains won’t be an entirely new concept.

7. Incorporation of CMMC Into Non-Governmental Sectors

After its eventual expansion into other federal organs, CMMC may subsequently pervade the non-governmental sector. This a trend that might well be ongoing, as there are no rules barring non-state actors from implementing CMMC controls.  

In fact, non-governmental organizations can benefit more by working with authorized C3PAO assessors than standard cybersecurity auditors.  

It’s also worth noting that NIST controls, CMMC’s central pillar, are premised on globally validated cybersecurity guidelines. So, international organizations may equally adopt CMMC to bolster their cybersecurity posture.

8. Enhanced Cost Management  

There has been growing disquiet in the DIB since the unveiling of CMMC 2.0 in October 2024.  

First, many vendors voiced concerns about the program’s tight implementation deadline.  

While CMMC will undergo phased implementation over four years, the DoD set the effective date for initial compliance at December 16, 2024. This was exactly two months after publishing the Final Rule, in which many existing contractors were insufficient to rally the necessary resources for assessments and certification.  

There’s also the question of standardized fees. Although certification costs vary by each maturity level, CMMC makes no exception for smaller businesses.  

As concerns about inhibitive CMMC certification costs mount, we might expect the DoD to introduce a better cost management formula for disadvantaged vendors. However, DIBs can rest assured that the state agency will not undo all gains realized towards creating a hacker-proof defense supply chain.  

Until then, contractors can implement several strategies to manage CMMC certification costs. For instance, only schedule assessments based on the type of CMMC data your company handles.  

Let’s say your business only deals with federal contract information. In that case, you could simply focus your CMMC assessments on Level 1, which can be as low as $5,000. Spending ten times the amount for Level 2 audits makes no economic sense if your business doesn’t handle controlled, unclassified information.  

Another way to minimize CMMC certification costs is by implementing robust controls to forestall revenue losses caused by successful breaches.  

Prepare For the Future by Attaining CMMC Compliance Today 

CMMC compliance is no longer required only for prime defense vendors operating locally. It now applies to all businesses that manage FCI or CUI assets, including small traders and foreign companies. These are some of the most significant reforms in the recently unveiled CMMC framework, a testament to the program’s constant evolution.  

As we forge into the future, we’re likely to witness even more transformations to the CMMC framework and the cybersecurity landscape in general.  

Attaining CMMC compliance isn’t enough. You’ll need to keep your ears out for emerging trends and align your cybersecurity architecture appropriately.  

By being proactive, you can avoid costly CMMC non-compliance penalties while also improving your organization’s cyber hygiene.