Sum IT Up: CMMC News Roundup

Register for CMMC Industry Week: https://www.summit7.us/industry-week Since the 48 CFR CMMC final rule was published in September 2025 we've seen supplier notices from Lockheed, RTX, BAE, HII, and many others. Most recently, Northrop Grumman recently published a supplier announcement titled “CMMC 2.0 is Final – Are You Ready?”. The big takeaway: don't expect CMMC waivers from your prime customers because they can't grant them to you. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo DFARS 7012: https://youtu.be/cy4e28YAkXU?si=KvezY7Vu7zXf9qYZ 32 CFR Final rule: https://www.federalregister.gov/documents/2024/10/15/2024-22905/cybersecurity-maturity-model-certification-cmmc-program 48 CFR Final rule: https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of January Memo (PDF): https://dodprocurementtoolbox.com/uploads/DOPSR_Cleared_OSD_Memo_CMMC_Implementation_Policy_d26075de0f.pdf

While everyone has been focused on the start of CMMC phase 1, many contractors are discovering that DFARS clause 252.204-7020 has been lurking in their contracts since 2020. DoD reserves the right to show up at any time and audit compliance with DFARS clause 252.204-7012. This week we're diving into everything that DIBCAC will be asking for when they show up on your doorstep. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo DIBCAC intake forms: https://www.dcma.mil/DIBCAC/ DFARS 252.204-7012: https://youtu.be/cy4e28YAkXU?si=x4tmDKcCc44dLnJE DFARS 252.204-7020: https://youtu.be/D4JLkfvB-Ws?si=6_yyMYrU7DVoxoBt

The final Cyber AB TH of 2025 took place this week which means it's time for the team to unpack all the important information you need to know. On this week's show, Jason and Joy sit down for one one last time in 2025 as we discuss things like: •The final ecosystem update of 2025 •The biggest highlights of 2025 •DO I have to affirm my C3PAO assessment score? •What the AB expects for 2026 Tune in as we close out this year of Cyber AB Town Halls with a little fun! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

As of November 10th, 2025, CMMC is now a condition of award for new defense contracts. “Phase 1” of the CMMC rollout will last until November 10th, 2026. This week we discuss seven predictions we have for the new normal. Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 32 CFR 170.3(e): https://www.ecfr.gov/current/title-32/part-170#p-170.3(e) DFARS 7012: https://youtu.be/cy4e28YAkXU?si=yC_wKI42JNxIHKME Phase 1 Blog: https://www.summit7.us/blog/cmmc-begins-today

After four years of rulemaking here we are at the last podcast before the official start of CMMC phase 1. What better way to usher in the new normal of CMMC than a quick refresher on how and why CMMC became a thing in the first place? Nothing helps contextualize the CMMC program like remembering how resistant the DoD has been to third party verification until they were left with no other choice.

On this week's spine-tingling episode of the show, Jason and Joy sit down unwrap the October Cyber AB Town Hall like a bag of pillowcase full of candy. With less than two weeks until the November 10th launch, this marks the final town hall before the CMMC becomes a fully operational reality. Tune in as we mix up a cauldron of all the important information you need to know to assure no tricks as you pursue your CMMC bag of treats… no costumes required! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

CMMC officially goes into effect on November 10th, 2025, at which point all new DoD solicitations and contracts will include at least CMMC Level 1 status requirements. While the government shutdown might affect the pace of new contract awards, it doesn't change anything about the effective date of CMMC specifically. This week we're looking at the trickle of contract notices that are letting people know CMMC is very real and will absolutely be required (including level 2). Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo NAVSEA (Level 2): https://sam.gov/workspace/contract/opp/0a92f866231546828b3fd11cf1146a8a/view USSOCOM (Level 1): https://sam.gov/workspace/contract/opp/eb3d38dd00e845579212f724b6dedd37/view USACE (Level 2): https://sam.gov/workspace/contract/opp/e0a817b5b7c74c319ebaa2df9cd3d637/view

The Senate has passed their version of the FY26 NDAA and they want annual contractor performance measurements to focus exclusively on “negative performance events”. Per the Senate Armed Services Committee that includes failing to meet cyber requirements, failing to flow down requirements to subcontractors, and submission of false claims (cyber). Add this one to the growing pile of evidence that the government really, really wants contractors to take cybersecurity seriously. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Memo: https://dodcio.defense.gov/cmmc/Resources-Documentation/ Senate NDAA: https://www.congress.gov/bill/119th-congress/senate-bill/2296/text

Watch full webinar here: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here The start of CMMC phase 1 is just around the corner. Starting on November 10th, 2025, DoD contracting officers will begin inserting CMMC status requirements in new solicitations and contracts. We recently held a webinar on the CMMC final rule to get people up to speed so this week we're bringing you our key takeaways. If you want all the details, the webinar is available on demand (registration link is in the show notes). Find out where you are on your CMMC journey here: https://www.summit7.us/pathfinder

September has come to a close and despite all the moving parts, name changes, and other potential roadblocks, the CMMC program is humming along. Assessments are being conducted at a blazing pace, the AB staff is growing, and people are still not sure if they should identify as an ESP or CSP.On this week's show, we dig into the September Cyber AB Town Hall and break down all the important details you need to know! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

DFARS clause 252.204-7021 goes into effect on November 10th, 2025, but there's more under the hood than just the text of the contract clause. Contracting officers have an entire set of procedures they must follow that dictate when and if the 7021 clause should be included in a defense contract at all. In this episode we're looking at the other side of the coin to the infamous CMMC DFARS clause. Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874 Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of DFARS 7008: https://youtu.be/vgrRGIWboKc?si=chKYMNRUea9eqpn- DFARS 7012: https://youtu.be/cy4e28YAkXU?si=OO3IEXYvfGqZQ3op DFARS 7019: https://youtu.be/7gW_82Cus7Y?si=IT2ORlBlZELxxbdu DFARS 7020: https://youtu.be/D4JLkfvB-Ws?si=-hMhIq6dJLxu1NU4 DFARS 7025: https://youtu.be/LtJK-CHuyp8?si=A6WoUGBEEgVxp5Jx DFARS 7009: https://youtu.be/kfecRRrd41w?si=PNXrbcvRLHc5GoUg 32 CFR 170 Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule?_gl=1*1qpc6eg*_up*MQ..*_gs*MQ..

Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874 The regulation that finalizes CMMC guidance for DoD contracting officers and program managers officially goes into effect on November 10th, 2025. The highlight of the regulation is the final text of DFARS clause 252.204-7021 which tells contractors which CMMC level they need to achieve in order to take award of a contract. But the regulation also created DFARS provision 252.204-7025 which officially notifies offerors of the requirements contained in the 7021 clause and it's only three paragraphs long! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of

Register for the upcoming webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here It's official: CMMC Phase 1 begins on November 10th, 2025 when the 48 CFR CMMC final rule goes into effect. After that point all new Department of Defense/War contracts will contain some level of CMMC requirement. But just when things seem certain, people are wondering about the recent class deviation regarding DFARS clause 252.204-7021. Is the use of the CMMC clause actually suspended? Spoiler: no, not even close. Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874 Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of Aug Class Deviation: https://www.acq.osd.mil/dpap/policy/policyvault/USA001756-25-DPCAP.pdf

A lot of defense contractors are betting that the DoD will only require CMMC Level 2 self-assessments during the first 12 months of CMMC (“Phase 1”). Since December 2024 there have been three official policies outlining what can be required in Phase 1 and none of them prohibit Level 2 certification assessments. Instead, every policy we can find reinforces the idea that many companies will be required to achieve CMMC Level 2 certification in Phase 1. In this episode we walk through all 3 policies so you can decide for yourself if that's a risk you want to take with your business. Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 32 CFR 170.3(e): https://www.ecfr.gov/current/title-32/part-170#p-170.3(e) The January Memo (PDF): https://dodprocurementtoolbox.com/uploads/DOPSR_Cleared_OSD_Memo_CMMC_Implementation_Policy_d26075de0f.pdf The July Memo (PDF): https://dodprocurementtoolbox.com/uploads/PTDO_Do_D_CIO_Memo_Resources_for_CMMC_Implemtation_dtd_20250728_25_T_2704_cleared_20250807_e53aa02e78.pdf

The Summer is all but over, but that's ok because the CMMC program is just getting started! On this week's episode, we cover the Cyber AB's Monthly Townhall for August and break down all the things you need to know. Things like: • Did assessment progress slow down? • Are there any reported failures? • Are people finally interpreting the 10-day post assessment rule correctly? • Will the DoD be represented at CS5? • What is the C3PAO Advisory Council? And so much more... Tune in to find out! Summit 7 Live: https://www.summit7.us/S7Live Women of CMMC Dinner: https://cs5global.org/women-of-cmmc-dinner/ Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025 Golden Dome promises to be the largest and most complex defense initiatives in American history. Countless contractors, subcontractors, and suppliers will be called on to help build the ultimate system of systems. But those suppliers are the targets of cyber espionage, disruption, and IP theft – regardless of their size. So it's no surprise that as the Golden Dome program lifts off, the DoD is out in front with some pretty intense cybersecurity requirements. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo DFARS 7012: https://youtu.be/cy4e28YAkXU?si=KvezY7Vu7zXf9qYZ

Register for Secure The DIB: https://securethedib.us/ Voluntarily disclose your DFARS cybersecurity noncompliance? That'll be $1.75M, please. This week we're looking at the details of a recent False Claims Act settlement involving a small defense contractor. Turns out that mistaking export controls for cyber controls and relying on the wrong external service providers can controls can cost you a lot of money. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo DOJ Settlement: https://www.justice.gov/opa/pr/california-defense-contractor-and-private-equity-firm-agree-pay-175m-resolve-false-claims DFARS 7012: https://youtu.be/cy4e28YAkXU?si=KvezY7Vu7zXf9qYZ

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025 We can't remember a 30-day stretch in the history of CMMC that had more milestones and memos than July 2025. The ecosystem is closing-in on 300 Level 2 certified companies, mega primes have put everyone on notice, the phased roll-out is weeks away, the secretary of defense, the Army Corps of Engineers, you name it – everybody is gearing up for the big day. This week we're talking about 5 things you might have missed while on summer vacation. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Secure the DIB: https://www.summit7.us/secure-the-dib-2025 Lockheed Memo: https://youtu.be/gMHWhXhe_Uo?si=FtkziMSqBWfzWAWp SECDEF Memo: https://media.defense.gov/2025/Jul/22/2003759081/-1/-1/1/ENHANCING-SECURITY-PROTOCOLS-FOR-THE-DEPARTMENT-OF-DEFENSE.PDF 48 CFR Progress: https://youtu.be/Q2qeJhA4oIs?si=b1bRqxcR0MbTOWIj USACE Notice: https://sam.gov/workspace/contract/opp/0b14a472d53b454ea6bca0893b2647d0/view

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025 The Cyber AB brought the CMMC Ecosystem together once again for the July 2025 installment of their monthly Town Hall series. Join us for this week's show as we discuss all the information distributed during the meeting that you need to know; answers to questions like: After your assessment, you get 10 days to do what? How many CMMC assessments took place in July? Does anyone fail their assessment, and do they keep track of them? And so much more... Tune in to find out! Secure the DIB: https://www.summit7.us/secure-the-dib-2025 CMMC Just Crossed A *Huge* Rulemaking Milestone: https://youtu.be/Q2qeJhA4oIs?si=IQ1bYI6jH3VGuxAa Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025 The final rule that allows DoD to include CMMC requirements in defense contracts and solicitations has officially moved into regulatory review. This is the last milestone before official publication and the start of the CMMC “phased roll-out". Because this final rule simply implements CMMC policy that went into effect in December 2024, we believe CMMC will start showing up in contracts as early as late October. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Secure the DIB: https://www.summit7.us/secure-the-dib-2025 Self-Assessments/Waivers: https://youtu.be/LTgmrsFGr9s?si=jm7U4s4vQpgvj4J- PALT: https://youtu.be/NZs4f5voyrg?si=mjzethgW61SLad7t