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  • The Future Of CMMC: What’s Next For DoD Cybersecurity Compliance

The Future Of CMMC: What’s Next For DoD Cybersecurity Compliance

Patrice Shankman 4 min read
26

The Cybersecurity Maturity Model Certification (CMMC) confirms the existence of cybersecurity controls in defense contractors to safeguard classified government data.

Over the years, contractors attested themselves to being secure. Widespread data breaches confirmed that this model was ineffective.

CMMC is a radical transformation of compliance from a checkbox to doing business. It directly affects your contracting opportunities in DoD.

CMMC establishes new enforceable standards in the entire cybersecurity environment. The program isn’t static. The framework will change as the cyber threats do.

This article explores further into the future of CMMC — trends, changes, and strategic implications that will characterize the next level of DIB cybersecurity. Let’s dive in.

Table of Contents

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  • Current State of CMMC
  • Key Emerging Trends Influencing CMMC Evolution
    • 1. Heightened Focus on Supply Chain Cybersecurity
    • 2. Increasing Adoption in Zero Trust Architecture Concepts
    • 3. Shifts Towards Continuous Monitoring and Real-Time Compliance Verification
    • 4. Influence of AI and Automation on Compliance Processes
  • Essential Changes to Expect in CMMC Framework
  • Key Implications for Defense Contractors
  • Conclusion
    • About Author
      • Patrice Shankman

Current State of CMMC

The CMMC experience started with CMMC 1.0, an elaborate five-level framework. It was expensive and challenging for the Defense Industrial Base, particularly for small businesses. Late in 2021, DoD shifted to CMMC 2.0.

This lean structure consists of three levels and is based on the current world standards. The last rules were issued in 2024 and 2025, which preconditions the gradual implementation.

CMMC Level 2 is a continuation of the 110 security controls within NIST SP 800-171. CMMC 2.0 introduces a verification layer to make controls effective.

To overcome these challenges, one should have a clear knowledge of CMMC and its connection with NIST.

Key Emerging Trends Influencing CMMC Evolution

1. Heightened Focus on Supply Chain Cybersecurity

CMMC is a supply chain security program. Its development will place prime contractors in greater responsibility over subcontractor security. An adversary understands that the smallest, least safeguarded subcontractor is a hole in a prime network.

The value of flow-down requirements should be emphasized more, as primes need to actively confirm the CMMC status of their partners prior to sharing CUI.

2. Increasing Adoption in Zero Trust Architecture Concepts

The outdated castle-and-moat system of security is long gone. The new DoD standard is Zero Trust Architecture, which is based on the principle of never trust, always verify. Zero Trust relies on CMMC controls as a fundamental building block.

Zero Trust is created with the use of multi-factor authentication and least-privilege access. Studies indicate that the ZTA strategy can help contractors exceed and fulfill CMMC 2.0 requirements cost-effectively.

3. Shifts Towards Continuous Monitoring and Real-Time Compliance Verification

CMMC audits occur after every three years, yet the enemies strike daily. The future is shifting towards point-in-time audits to continuous monitoring.

The DoD desires evidence that security controls are 24/7. This promotes the use of tools that offer real-time dashboards and automated evidence gathering.

4. Influence of AI and Automation on Compliance Processes

Automation and artificial intelligence will have a significant effect on both sides of the CMMC equation.

As a Threat: The adversaries are also employing AI to develop more advanced phishing techniques and discover weaknesses more quickly.

As a Solution: AI and automation will help the contractors to protect themselves. This includes:

  • Automating CMMC control evidence collection.
  • Handling System Security Plans (SSPs) and Plans of Action and Milestones (POA&Ms) using AI-driven tools.
  • Implementing AI-based threat detection (such as SIEMs) to detect breaches instantly.

Essential Changes to Expect in CMMC Framework

The transition between CMMC 1.0 and 2.0 reduced the levels to three. Further development will be achieved later as the DoD collects the data from the initial round of testing.

CMMC 2.0 was broader than CUI. Level 1 focuses on contractors that deal with Federal Contract Information and have 15 basic controls. Cybersecurity has become a mandatory requirement for all contractors, who are verified annually.

There is a shift in assessment methodology. The monolithic one-size-fits-all audit is eliminated. It has been substituted with a flexible and tri-level assessment model:

  • Level 1 involves self-assessment every year.
  • Level 2 is divided into self-assessment and triannual C3PAO audits.
  • Level 3 involves government-directed evaluations by DIBCAC.

CMMC 2.0 aligns with NIST SP 800-171. Future updates will capture broader federal cybersecurity mandates, such as those by agencies such as CISA or GSA, to ensure DoD requirements are up-to-date.

Key Implications for Defense Contractors

The last rules spell the end of waiting. CMMC ceases to be an IT issue. It is a business-level strategy.

Contractors have to invest seriously. Do they develop expertise internally? Do they enlist a Managed Security Service Provider to administer a CMMC-conformant enclave? Or will they jeopardize missing out on future contracts? It needs planning at the level of the C-suite and a special budget.

The impact on the business is binary. Those firms that do not attain the necessary level of CMMC cannot bid or win new DoD contracts. This can create severe legal liability by making companies vulnerable to False Claims Act liability in case senior-level affirmation on self-assessment is incorrect. The DoD’s Civil Cyber-Fraud Initiative demonstrates that enforcement is a reality.

Early certified contractors receive an incredible competitive edge and become trusted partners.

Conclusion

CMMC has become a simplified NIST standards verification framework. Zero Trust, constant monitoring, and automation are also in its future. Its phased implementation started at the end of 2025. 

Start your gap analysis for NIST SP 800-171. Identify your necessary CMMC level. Get the professionals involved and plan to invest in technology and training.

CMMC secures the defense supply chain, defends American innovation, and protects national security. Begin your compliance quest now so that contracts are not taken away.

About Author

Patrice Shankman

See author's posts

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