National security is not a public relations exercise. Multiple findings have shown that when it comes to safeguarding sensitive government secrets, a slip-up can have far-reaching implications, both financially and reputation-wise.  

Unfortunately, many federal agencies have learned this vital lesson the hard way. That includes the U.S. Department of Defense (DoD), which has been the target of aggressive cyberattacks directed at its critical infrastructures.  

To strengthen national security, the DoD developed a robust cybersecurity framework known as CMMC. All prospective Defense Industrial Base (DIB) companies must adhere to the cybersecurity protocols outlined in the CMMC program or risk costly penalties.  

Released in January 2020 as CMMC 1.0, the DoD’s CMMC program has undergone robust reforms to align with emerging threats to national security. The framework’s latest version – CMMC 2.0 – became operational on December 16, 2025, heralding the introduction of mandatory compliance for all DIB companies.  

With CMMC requirements poised to start appearing in select DoD contract solicitations around mid-2025, the clock is fast ticking for organizations seeking compliance (OSCs).  

But why did the DoD introduce mandatory CMMC compliance for its contractors, and what are the implications of skimping on these requirements?  

This blog explores those questions in detail. 

Unveiling CMMC

The Cybersecurity Maturity Model Certification, more commonly abbreviated as CMMC, is a framework developed by the DoD to streamline cybersecurity compliance for all DIB organizations.  

CMMC seeks to protect the handling, storage, and dissemination of sensitive information. The program particularly targets Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).  

To comply with CMMC, defense contractors will need to schedule rigorous cybersecurity assessments regularly. Businesses that demonstrate strict adherence to the program standards receive certifications, increasing their competitiveness for defense bids.  

However, CMMC compliance isn’t a one-time event. DIBs must continually affirm their compliance status annually or triennially, depending on their respective maturity levels. 

CMMC Versus NIST

CMMC is primarily based on NIST, although both are distinct frameworks.  

Short for the National Institute of Standards and Technology, NIST outlines the best practices that organizations across multiple sectors can implement to manage cybersecurity threats. It differs principally from CMMC, which specifically targets defense contractors.  

Another striking distinction between CMMC and NIST is that CMMC is mandatory for all DoD vendors, whereas NIST is optional. 

Tracking Down CMMC’s Evolution from Voluntary to Mandatory Compliance

One of the top concerns of many would-be defense suppliers regards CMMC’s compliance obligations. So, is CMMC certification mandatory?  

To settle this question, we’ll need to trip back to CMMC’s origin and examine how the framework has evolved over the years.  

Before CMMC became existent, federal contractors (including DIB companies) were required to implement the cybersecurity standards highlighted in the NIST Special Publication (SP) 800-171. That’s the same NIST edition that the current CMMC framework primarily derives from.  

However, compliance with these requirements was largely voluntary. Contractors could simply self-assess and report on their compliance status in the DoD Supplier Performance Risk System (SPRS).  

However, with the absence of third-party validations, some vendors were skimping on regulatory cybersecurity audits. Others skipped the process altogether, completely misreporting their actual cyber posture.  

These underhanded practices led to a spike in successful cyberattacks directed at the DoD. Something had to be given, and it sure did.  

In 2010, President Barack Obama signed Executive Order 13556, which defined CUI and what it constitutes.  

In 2019, the DoD announced that it was developing the CMMC framework. The federal agency signaled that the new framework would be a departure from the self-attestation security model that presently existed for its contractors.  

CMMC was developed as a joint effort between the DoD and critical industry stakeholders, including university researchers.  

In January 2020, the DoD released the first iteration of CMMC – CMMC 1.0. The framework originally included five maturity levels, which have since been condensed to three. CMMC 1.0 underwent robust reforms, culminating in the release of CMMC 2.0 in October 2024.  

Why Is CMMC Compliance Mandatory?

CMMC was developed to protect sensitive data from unauthorized access. As mentioned, the framework’s creation was inspired by persistent cybersecurity threats to the defense supply chain.  

The Department of Defense deals with vast amounts of information. Most of this data is included in federal contracts, increasing its access to unauthorized actors.  

Assume that the DoD contracts with a renovation company to overhaul the plumbing systems in one of its critical installations. To deliver this role, the contractor may require the property’s architectural blueprint.  

If the company is too reckless or greedy, the sensitive blueprint in its possession could slip into the hands of the US’ military enemies, with catastrophic repercussions.  

But these incidents aren’t merely a figment of the imagination. Cyber-attacks targeting the defense supply chain have spiked in recent years, with the SolarWinds incident of 2020 underscoring the vulnerability of federal agencies back then.  

The SolarWinds attack occurred when hackers exploited a deficiency in the SolarWinds’ Orion software platform to access sensitive data of numerous government agencies, including the DoD. When the dust settled, approximately 18,000 customers had their data potentially exfiltrated and compromised. Some forensic reports estimate the total insured losses from the SolarWinds cyber-attack at $90,000,000.  

Barely a year later, the DoD (alongside other government organizations) became a target of yet another major cyber-attack – the Colonial Pipeline. This breach occurred when a cyber entity known as DarkSide seized control of the Colonial Pipeline servers, demanding a hefty ransom.  

Following the attack, the Colonial Pipeline suspended its operations for five days. The shutdown significantly impacted the pipeline’s clients, including the DoD.  

By mandating CMMC compliance, the DoD seeks to avert the recurrence of similar threats. Defense contractors will now play a proactive role in safeguarding sensitive military information, preventing malicious actors from exploiting national security vulnerabilities. 

What Are The Consequences Of Non-compliance?

1. Ineligibility for Defense Tenders

The United States military is the most heavily funded globally.  

With defense expenditure exceeding $997 billion in 2024, the DoD provides lucrative business opportunities to qualifying suppliers. Obtaining CMMC certification is a critical eligibility criterion.  

To maximize your defense opportunities, you must demonstrate due compliance with the CMMC controls under your respective maturity level. Non-compliant firms are automatically knocked off the merit list.

2. Contract Termination

Mandatory CMMC compliance applies to both aspiring and existing defense contractors. Vendors that miss crucial compliance deadlines risk having their contracts terminated.  

Losing a lucrative contract may lead to significant revenue losses, crippling your operations. It could even have you wind up, especially if the DoD is your principal client.

3. Lawsuits

Failure to comply with the DoD CMMC may also lead to costly lawsuits.  

A case in point occurred in October 2024, when Pennsylvania State University (Penn State) agreed to pay $1.25 million in settlement for a False Claims Act (FCA) lawsuit.  

Penn State allegedly failed to adhere to cybersecurity standards in fifteen contracts with the DoD. The institution specifically misreported compliance with NIST 800-171, which the CMMC is largely based on.

4. Financial Penalties

The DoD presently doesn’t impose direct financial penalties on CMMC for non-compliant vendors.  

However, it’s logical to surmise that the agency may consider such ramifications to enforce strict compliance.  

Besides, losing existing contracts and getting blacklisted from bids is devastating enough.

5. Reputational Damage

Failure to meet CMMC’s standards exposes your business to cybersecurity threats. Successful breaches can harm your reputation, deterring potential clients and partners.  

Even if you’re not angling for defense contracts, skimping on CMMC compliance can put your organization in the spotlight.  

Many people are growing increasingly wary of cybersecurity threats and will shy away from companies that implement lackluster security controls. 

Who Needs CMMC Compliance?

Compliance with the CMMC framework is mandatory for all DIB companies. Those include; 

• Prime contractors 
• Subcontractors 
• Vendors & suppliers 

However, DIB companies differ in the required compliance level.  

To determine the proper CMMC assessment for your business, review your contracts for Federal Contract Information and Controlled Unclassified Information.  

Companies that handle FCI must comply with CMMC Level 1. 

Considered the foundational level, Level 1 aligns with 17 controls in the Federal Acquisition Regulation (FAR) Clause 52.204-21. It requires annual self-affirmations, although the DoD now implements stringent measures to enforce accountability.  

If your business handles CUI, you’ll need to adhere to 110 cybersecurity standards outlined in the NIST SP 800.171, which constitute Level 2. 

Most DIBs fall under this maturity level. Unlike Level 1, which allows self-assessment, Level 2 audits must strictly be undertaken by an authorized third-party assessor organization (C3PAO).  

C3PAOs play a critical role in enforcing CMMC compliance. Findings from C3PAO-led audits are reported to the CMMC Accreditation Body (AB), possibly culminating in the issuance of CMMC certification.  

CMMC’s most advanced level, Level 3, aligns with all Level 2 controls plus 24 additional standards in NIST SP 800-172.  

Level 3 seeks to secure the defense supply chain from Advanced Persistent Threats (APTs). All assessments are overseen by an official from the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).  

Expedite CMMC Compliance With Professional Assistance

Navigating the CMMC compliance landscape can be overwhelming, particularly for defense suppliers that lack advanced cybersecurity know-how. The process is even more daunting when you consider the appallingly low rate of approved C3PAOs vis-à-vis the thousands of DIBs seeking cybersecurity audits.  

Fortunately, you don’t have to go it alone.  

Cybersec Investments delights in assisting businesses accelerate their CMMC compliance, providing them with a critical incentive in the competitive DIB landscape. We acknowledge that obtaining CMMC certification is a resource-intensive endeavor.  

To ease the process, Cybersec undertakes to offer swift, in-depth, and objective audits. All our evaluations are conducted by authorized C3PAOs with a technical understanding of CMMC and other relevant federal security programs. Contact us today, and we’ll readily dispatch a representative to discuss further modalities.