Sum IT Up: CMMC News Roundup—Key Takeaways From Our Final Rule Webinar

Podcast Host: Summit 7
Episode Air Date: October 9, 2025

Episode Overview

This episode distills urgent updates following the release of the final CMMC (Cybersecurity Maturity Model Certification) rule, as Summit 7 recaps main points from their recent in-depth webinar. The hosts focus on actionable advice for defense contractors—especially as the November 10, 2025 phased rollout draws near. They aim to dispel common myths, highlight critical takeaways, and provide practical guidance regarding compliance strategies, the reality of enclave solutions, and the organizational challenges ahead.

Key Discussion Points & Insights

1. November 10, 2025: CMMC Phased Rollout Begins

• Main Point: CMMC level requirements will start appearing in Department of Defense (DoD) solicitations and contracts—including task orders and purchase orders—starting November 10, 2025.
• Enforcement: CMMC status (often Level 2, requiring third-party assessment) can be a condition of award.
• Timestamps: [00:18]–[01:10]

> “Starting on November 10th of 2025, DoD Contracting Officers will begin specifying CMMC status requirements in new solicitations and contracts...as a condition of award…”  

> —Speaker A [00:18]

2. Misconceptions Around Certification Requirements

• Critical Clarification: Contrary to widespread belief, Level 2 third-party (C3PAO) assessments can be required in Phase One—not just self-assessment.
• Don’t Count on Waivers: Expecting waivers or leniency is risky; the requirements are more immediate than many realize.
• Do Not Assume Self-Assessment is Sufficient: Organizations betting on self-assessment risk being excluded if a certification assessment is required.
• Timestamps: [01:12]–[01:59]

> “Contrary to popular belief, CMMC Level 2 C3PAO status...can and will be required during the first 12 months of the phased rollout...This is probably the biggest takeaway…”  

> —Speaker A [00:55]

3. Contractor Strategies: Urgency and Planning

• Check Acquisition Forecasts: Companies should review their government customers’ long-range acquisition forecasts to back-calculate timelines, budget, and implementation plans.
• Timing is Tight: The window for compliance may close faster than expected; plan backward from contract goals.
• Timestamps: [01:37]–[02:19]

> “The number one thing...is to check your government customers’ long-range acquisition forecast...”  

> —Speaker A [01:37]

4. Prime vs. Subcontractor Considerations

• Subcontractors: Requirements may be dictated by primes, not the government directly—communication with the prime is crucial.
• Real-World Example: Boeing’s messaging in their newsletter: “Act now.”
• Timestamps: [02:24]–[02:54]

> “If you’re a subcontractor, talk to your prime...they are going to be the ones that set your requirement. It’s not the government.”  

> —Speaker B [02:39]

5. Reality of Enclave Solutions

• Not All Enclaves Are The Same: Two main kinds—cloud-based (all VDI, Microsoft GovCloud) and hybrid (including some on-premise elements).
• Hybrid is Often Practical: Most organizations will need hybrid enclaves, especially if printers, workstations, or mobile devices are in scope.
• Scope Missteps: Buying an enclave without properly scoping for contract needs can result in costly rework and inability to fulfill contracts.
• Vendor-Owned vs. Customer-Owned Enclaves: Having a vendor set up an enclave under your own company’s subscription offers more flexibility for future needs or boundary changes.
• Timestamps: [05:32]–[09:10]

> “There’s kind of two versions of an enclave...a cloud-based enclave...That’s not practical for a lot of people...most organizations have to end up leaning towards a hybrid enclave..."  

> —Speaker C [05:32]

> “If you need to extend your boundary, how easy is it to do if you’re locked into a VDI subscription with somebody else?...Significant architectural change...triggering of a recertification.”  
> —Speaker C [08:25]

6. Organizational and Cultural Challenges

• CMMC is Not Just an IT Problem: Organizational change and executive buy-in are harder than technical implementation.
• Common Blockers: Delays in simple decisions (e.g., domain names), lack of policy sign-offs, and senior management reluctance—these slow or stall CMMC projects more than the tech issues.
• Notable Anecdote: One company has delayed a decision for a year just to choose a domain name.
• Timestamps: [03:10]–[05:32]

> “The problem isn’t the technology...it’s your policies...changing the culture of your organization and how you function...That takes time.”  

> —Speaker B [03:23]

> “CMMC is not an IT problem...organizational adoption, that’s the long pole.”  
> —Speaker C [03:32]

> “We can have you up and running as fast as you want to go. And we don’t hear from them for months because approvals, budgets, decision makers...the problem is not the technology.”  
> —Speaker A [03:44]

7. Prime/Sub Tracking & Environment Scope

• Linking Subcontractors to Enclosures: Primes need methods for tying subcontractors’ unique identifiers (UIDs) to the relevant enclave for processing CUI.
• Lessons Learned: Early standalone enclave certifications didn’t always reflect actual secure processing.
• Looking Ahead: Phase two of rulemaking is expected to tighten controls and close existing gaps.
• Timestamps: [06:55]–[07:57]

> “I gotta figure out how primes are going to deal with this—how do they tie the UIDs of their subs to the scope of the processing...?”  

> —Speaker B [06:55]

Notable Quotes & Memorable Moments

• Biggest Misconception:

  “This is probably the biggest takeaway that you can get out of this webinar.”
  —Speaker A [00:59]

• On Executive Buy-In:

  “I talk to people all the time—they can’t even get a senior official to sign the documents required...That’s a healthy fear, but also it shows how out of sync executives can be...”
  —Speaker C [04:03]

• Cultural Roadblocks:

  “It would be interesting to see how many times it’s taken longer to pick a domain name than it has for the DoD pulp window to close...”
  —Speaker A [05:10]

• On Enclave Flexibility:

  “We can expand your boundary a lot easier...than if you’re buying like a $200 a month seat for a hosted virtual desktop that somebody else owns.”
  —Speaker C [08:25]

Conclusion: Key Actions for Listeners

• Act Now: Don’t delay CMMC preparations—requirements are arriving in months, not years.
• Maintain Active Communication: Especially if you’re a subcontractor; stay in close contact with your primes about requirements.
• Strategic Enclave Planning: Choose an enclave architecture that will scale with your future contracts and operational changes.
• Prioritize Organizational Alignment: IT alone can’t get an organization compliant—executive engagement and cultural adaptation are essential.
• Plan Backwards: Use acquisition forecasts to structure your compliance roadmap.

To dive deeper or access all the finer points, listeners are encouraged to view the full webinar as referenced by Summit 7.