Sum IT Up: CMMC News Roundup

Episode: 7 CMMC Predictions for 2026

Date: January 1, 2026
Host: Summit 7

Overview

In this special year-end episode, Summit 7 recaps their 2025 CMMC predictions—boasting a 71% accuracy rate—and dives into seven bold predictions for the world of CMMC in 2026. With a healthy dose of humor and insider insights, the hosts review regulatory progress, government reports, and enforcement trends, while forecasting the road ahead for CMMC, DFARS, FAR, and related cybersecurity requirements for defense and federal contractors.

Recap: How Did the 2025 Predictions Turn Out? (00:54–13:49)

2025 Hits and Misses:

• False Claims Act (FCA) Settlements: Predicted an uptick, especially among small businesses. Multiple settlements materialized, with substantial fines and whistleblower payouts.
• DFARS 252.204-7012 Revision: Predicted publication of the proposed rule—did not happen. No substantial progress or indication it’s imminent.
• FedRAMP Equivalency: Expected removal via rulemaking; did not occur, and strict equivalency still stands.
• C3PAO Accreditation Audit: Predicted DoD IG report would not disrupt the program. It was a "nothing burger" with no major issues found.
  • “This was a small debate...So we released a four part episode series...Didn’t turn out to be anything at all.” — A [07:17]
• 32 CFR Final Rule: Predicted it would publish before the election—true. Rule was finalized and phased rollout began.
• FAR CUI Rule (Proposed): Predicted publication; happened in January 2025. Introduces NIST SP 800-171 for all federal contractors.
• NIST SP 800-172 Rev 3 Expansion: Predicted a 25%+ increase in controls; confirmed as requirements increased dramatically.
• Bonus AI/Critical Infra. Incident: Predicted a major incident involving AI in critical infrastructure; partially correct, especially noting deepfakes and social engineering ("half credit").

Memorable quote:
“If you only read [IG report] summaries, it makes everything sound really bad all the time. That’s their business model...You have to read the whole thing.” — A [06:13]

Seven CMMC Predictions for 2026

1. CMMC Level 2 Surge: 1,000+ Certifications by March, 2,500+ by Year-End (14:36–16:14)

• The hosts predict over 1,000 organizations will achieve Level 2 CMMC certification by March 2026, and at least 2,500 by year’s end.
• Debate on the pace: recent trends suggest growth, but March is a tight window.
  • “Here we are just hitting January, and I don’t know, that’s, that’s a lot. That’s short.” — B [15:22]
• Ultimately, both agree it’s achievable as demand and assessment capacity ramp up.

2. Dozen+ False Claims Act Settlements—with Steep Fines (16:22–18:51)

• At least 12 FCA settlements with defense contractors expected in 2026 (vs. 5 in 2025).
• Most will include seven-figure penalties, with fines tied to contract value.
  • “Not trying to scare anybody, but it is true that there are companies of all sizes getting hammered for $800,000 here, $1.75 million there, $4 million over here throughout the year.” — A [17:41]
• Expect ongoing, high-profile enforcement activity.

3. No Major Funding to Cover Costs (18:51–21:09)

• No significant appropriations or grants to offset CMMC or DFARS 7012 compliance costs in 2026.
• CYBERSEC will continue as overhead for contractors, with little to no external relief.
  • “Help is not coming. There will be no major funding appropriation.” — A [19:19]
• Tax incentive legislation momentum has also faded.

4. FAR CUI Final Rule Will Publish and Take Effect by Year-End (21:22–23:10)

• The much-anticipated FAR CUI rule is predicted to publish and become effective before the end of 2026—after major overhaul delays in 2025.
• This would standardize CUI requirements across all federal contracts but with agency-level autonomy over assessment models.
  • “This makes the 800-171 baseline the requirement for all federal contractors handling CUI…We’ve been waiting on this thing for over a decade.” — A [22:22]
• Co-host B is skeptical it will publish in 2026, but A remains optimistic.

5. CMMC 3.0 Proposed Rule Will Publish Before Halloween (23:19–25:23)

• Anticipate the 3.0 version (32 CFR rev.) will be released pre-Halloween, updating standards to NIST SP 800-171 and -172 Rev 3, and integrating DOD’s new parameters.
• CMMC 3.0 would not require new 48 CFR updates as it will reference the latest 32 CFR text.
  • “This rule should…take less time because they’re not creating it from scratch, they’re just revising it.” — A [25:02]
• Both hosts are confident, citing progress and established groundwork.

6. First CMMC Level 3 Solicitation—Ahead of Schedule (25:24–27:59)

• At least one solicitation in 2026 will require CMMC Level 3, ahead of phased rollout timing.
• CMMC PMO is piloting Level 3 assessments already; high-priority/critical programs poised to move early.
  • “The writing on the wall for Level 2 is that it’s there. The writing on the wall for Level 3 is that it’s there.” — B [27:05]
• Key example: ‘Golden Dome’ programs highlight urgency.

7. GAO CMMC Report: Another “Nothing Burger” (27:59–29:34)

• The upcoming Government Accountability Office report will deliver no major findings, derailing controversies, or material issues.
• Program is highly scrutinized; prior major reviews have been uneventful.
  • “This GAO report was supposed to come out at the end of 2025…the CMMC program has to be one of the most extensively reviewed and analyzed and evaluated programs that the DoD has ever undertaken.” — A [27:59]
• Anticipate a Q1 release; expect detailed coverage in future episodes.

Notable Quotes & Memorable Moments

• “We were pretty accurate for our predictions in 2025, and we’ve got a bunch of spicy ones coming up for 2026.” — A [00:05]
• “If one of the bets doesn’t hit in the parlay, the parlay didn’t hit.” — B [04:26]
• “It was such a nothing burger that we did a four part episode going through every single page of the IG report.” — A [06:10]
• “Help is not coming. There will be no major funding appropriation. What do you think?” — A [19:19]
• “Trick or treat, everybody. You’re going to get the revision!” — A [25:09]
• “This is a...Did I convince you? I don’t know.” — B [27:05]

Timestamps for Key Segments

• 00:54 — Review of 2025 predictions: accuracy rates, notable outcomes
• 14:36 — Prediction #1: CMMC Level 2 certification surge
• 16:22 — Prediction #2: FCA settlements and penalty forecasts
• 18:51 — Prediction #3: Funding gap remains
• 21:22 — Prediction #4: FAR CUI final rule by year-end
• 23:19 — Prediction #5: CMMC 3.0 rule by Halloween
• 25:24 — Prediction #6: First CMMC Level 3 solicitation
• 27:59 — Prediction #7: Quiet GAO report expected

Tone & Takeaways

• The hosts blend deep regulatory insight with sharp wit—keeping complex topics accessible, skeptical, and even playful.
• Their predictions for 2026 focus on continued regulatory tightening, stepped-up enforcement, process delays, and resource challenges for contractors.
• The podcast offers direct, actionable takeaways for CMMC stakeholders, signaling increased scrutiny, little outside financial relief, and the critical importance of early compliance.

For the CMMC Community

• Share your own predictions or opinions on LinkedIn or in the comments.
• Stay tuned for follow-up episodes and deep dives on enforcement actions, regulatory updates, and assessment trends.
• Don’t expect miracles—compliance is a moving, expanding target. Start preparing sooner than later.

“Let us know what you think…We appreciate all of you.” — A [29:34]