Understanding the CMMC 2.0 Timeline

More than 100,000 companies in the military industrial base and 200,000 supply chain businesses will be affected to varying degrees as the U.S. Department of Defense rolls out a new cybersecurity mandate. The Cybersecurity Maturity Model Certification, routinely called CMMC 2.0, is already being phased into military defense contract proposals and will steadily trickle down to supply chain organizations through 2025. Decision-makers who kicked the can down the road on CMMC 2.0 compliance preparation could find themselves sidelined from the lucrative revenue of military contracts.

Business leaders who have delayed meeting CMMC 2.0 requirements or remain unsure about critical next steps would be well-served to contact a certified CMMC Third Party Assessor Organization (C3PAO) for guidance. This CMMC 2.0 timeline refresher reinforces the need for proactive efforts on the part of contractors and subcontractors the country relies on for materials, products and services.

CMMC 2.0 Compliance Milestones

To some degree, the federal government has made CMMC 2.0 compliance increasingly difficult for contractors and supply chain operations. The mandate traces its origins to Executive Order 13556, put forward by the White House in 2010.

The CMMC model was a forward-thinking policy designed to bring wide-reaching cybersecurity standards under one umbrella. The Pentagon found that applying different digital security obligations across the defense industrial base was counterproductive. Allowing organizations to self-assess and base cybersecurity compliance on trust wasn’t working. Companies would get hacked by advanced persistent threats funded by hostile nation-state actors like Russia, Iran and China, only to pay fines and incur suspensions after the fact.

Fast-forward to the next administration, and the Department of Defense announced a unified policy that effectively did away with self-assessments. Announcing CMMC 1.0, the Pentagon established five cyber hygiene levels. It also mandated oversight and transparency to ensure everything possible was done to deter and repel enemy nations from stealing American national security secrets.

But a change at the White House prompted a review of the policy. The new administration tapped the brakes at the eleventh hour, streamlining the five cyber hygiene levels to three in what has been hailed as CMMC 2.0. These are what military defense contractors and subcontractors can expect in terms of CMMC 2.0 compliance.

Level 1 (Foundational Cyber Hygiene)

Enterprises that store and transmit federal contract information (FCI) typically fall under the Level 1 standard. You can anticipate meeting 17 controls based on the National Institute of Standards and Technology (NIST 800-171) guidelines. The reason FCI data requires protection is that rogue nations use fragments of information to piece together larger national security measures.

If your company falls into Level 1 cyber hygiene, the Department of Defense may allow annual self-assessments. Stringent guidelines must be adhered to, and the results communicated to the federal government. C-Suite professionals will likely need to attest to the assessment findings.

Level 2 (Advanced Cyber Hygiene)

If your operation handles Controlled Unclassified Information (CUI), it may come under the Level 2 cyber hygiene protocol. Level 2 defenses follow 110 best practices primarily based on NIST SP 800-171. In some instances, companies may have the option of an annual self-assessment. Others may need to enlist the support of a C3PAO to conduct cyber hygiene testing every three years.

To say the Pentagon has created some confusion among Level 2 organizations would be something of an understatement. Military contractors and supply chain businesses that remain unsure are advised to contact a certified C3PAO.

Level 3 (Expert Cyber Hygiene)

The CMMC 2.0 requirements assigned to Level 3 are intense and stringent. Defense contractors and subcontractors that handle and transfer CUI and classified data are tasked with meeting more than 110 NIST SP 800-171 practices. They are expected to have the bandwidth to detect, deter and repel Advanced Persistent Threats backed by America’s adversaries and sophisticated hackers. The security mandates required Level 3 organizations to have a C3PAO conduct a thorough review and report the findings to the federal government every three years.

The Pentagon announced CMMC 2.0 timeline and compliance changes in November 2021. After two years of rulemaking, the mandate entered the final 60-day public comment leg of the journey. As we barrel ahead into 2024, companies face critical CMMC 2.0 timeline mandates.

Key CMMC 2.0 Timeline Considerations

It’s crucial for outfits that benefit from defense contracts to understand that regulatory compliance is already at hand. The Pentagon expects organizations to adhere to previously approved cybersecurity measures such as CMMC 1.0 to prevent threat actors from putting our soldiers in harm’s way. While filing assessments may not be mandated for every military industrial base enterprise, it’s prudent to onboard a managed IT firm with CMMC experience to make certain you meet Pentagon expectations. Again, a single data breach could sideline your company from revenue-generating work. That being said, this CMMC 2.0 timeline breakdown highlights how quickly the newly minted mandate is approaching.

• C3PAOs: The Department of Defense began training C3PAOs in 2021 to prepare for CMMC 2.0 assessments. With C3PAOs available, Level 2 and 3 evaluations can be voluntarily conducted. This gives industry leaders time to review their risk assessments and make changes in advance of the approaching mandate.
• Contract Appearance: The federal government notes that CMMC 2.0 will appear in contracts 9-14 months after publication. The interim rule was posted in November 2021. Companies can anticipate seeing CMMC 2.0 in contracts as early as 2024.

A complete phase-in is expected to be completed by 2025, and operations are expected to have upgraded their defensive postures accordingly. Level 1 and 2 outfits that can self-assess and report annually would be wise to utilize a CMMC checklist and contact a C3PAO to conduct a non-binding risk assessment. Those who need to meet the CMMC 2.0 requirements for Levels 2 and 3 would be well-served to schedule an assessment before the logjam of last-minute accreditation requests occurs.

CONTACT RED RIVER TO GET THE CMMC 2.0 PROCESS STARTED

The cybersecurity experts at Red River help businesses in the military industrial base meet the CMMC 2.0 requirements. If you are concerned about CMMC deadlines or need clarification on your current cybersecurity defenses, call us today or fill out our online contact form. Let’s get the process started!