CMMC Program Guidelines: Strengthening Cybersecurity Across the Defense Industrial Base

As cyber threats continue to escalate and adversaries grow more sophisticated, ensuring the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) has become a mission-critical priority for the Defense Industrial Base (DIB). The U.S. Department of War’s Cybersecurity Maturity Model Certification (CMMC) program represents a pivotal shift in how defense contractors must demonstrate and maintain compliance with federal cybersecurity standards.  

These updated requirements reflect a broader strategy: to improve national resilience by ensuring every contractor, subcontractor, and service provider handling defense-related information meets consistent, enforceable security expectations. 

CMMC is a tiered model designed to align cybersecurity maturity with the sensitivity of information handled. 

• Level 1 establishes the foundational safeguards needed to protect FCI.
• Level 2 introduces the full suite of NIST SP 800-171 controls to protect CUI.
• Level 3 adds enhanced protections from NIST SP 800-172 to defend against advanced persistent threats. 

These levels help organizations clearly identify their obligations, assess their readiness, and take the necessary steps toward compliance. Whether a small subcontractor or a large prime contractor, every organization plays a role in strengthening the overall security of the defense supply chain. 

With the 32 CFR Part 170 Program Rule and the forthcoming 48 CFR Part 204 Acquisition Rule, CMMC is transitioning from guidance to enforceable requirements. The Department of War’s phased rollout, beginning in November 2025, ensures that contractors have time to prepare before CMMC becomes mandatory for all relevant solicitations. 

Across the phases, organizations will see increasing expectations, shifting from self-assessments to third-party or government-led audits. Crucially, without the required CMMC certification recorded in the government’s supplier database (Supplier Performance Risk System or SPRS), contractors will be ineligible for awards, making early preparation not only smart, but essential. 

While the updated program does not introduce new technical controls, it significantly raises the bar for governance, documentation, and audit readiness. Organizations must be able to demonstrate consistent execution of NIST-aligned practices, maintain accurate inventories, and produce evidence of ongoing compliance. For many, this will require thoughtful planning, formalized processes, and clear internal ownership. 

Key preparatory steps include defining the scope of FCI/CUI, conducting readiness assessments, establishing a System Security Plan (SSP), and maintaining a Plan of Action & Milestones (POA&M). As CMMC requirements begin appearing in solicitations, early alignment will reduce the cost, risk, and disruption of last-minute compliance efforts. 

Sia brings deep regulatory, technical, and operational expertise to help clients navigate the complexities of CMMC certification. Our global team of cybersecurity professionals, with certifications such as CISSP, CISM, CISA, and ISO 27001, supports organizations through: readiness assessments, gap analyses, remediation roadmaps, evidence preparation, and continuous compliance management. 

We help clients translate requirements into actionable improvements. Our approach goes beyond checklist compliance to build sustainable, risk-informed security maturity tailored to each client’s environment and mission.