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It's difficult to keep up with all of the moving parts that make up the Department of Defense's Cybersecurity Maturity Model Certification Program. It's even more difficult to keep up with the relevant bits and bites that influence CMMC. This weekly podcast sums up the news and developments relevant to CMMC; DFARS and other regulations; and NIST standards such as SP 800-171, SP 800-53, the NIST Cybersecurity Framework, and others.

After four years of rulemaking here we are at the last podcast before the official start of CMMC phase 1. What better way to usher in the new normal of CMMC than a quick refresher on how and why CMMC became a thing in the first place? Nothing helps contextualize the CMMC program like remembering how resistant the DoD has been to third party verification until they were left with no other choice.

CMMC officially goes into effect on November 10th, 2025, at which point all new DoD solicitations and contracts will include at least CMMC Level 1 status requirements. While the government shutdown might affect the pace of new contract awards, it doesn't change anything about the effective date of CMMC specifically. This week we're looking at the trickle of contract notices that are letting people know CMMC is very real and will absolutely be required (including level 2). Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo NAVSEA (Level 2): https://sam.gov/workspace/contract/opp/0a92f866231546828b3fd11cf1146a8a/view USSOCOM (Level 1): https://sam.gov/workspace/contract/opp/eb3d38dd00e845579212f724b6dedd37/view USACE (Level 2): https://sam.gov/workspace/contract/opp/e0a817b5b7c74c319ebaa2df9cd3d637/view

The Senate has passed their version of the FY26 NDAA and they want annual contractor performance measurements to focus exclusively on “negative performance events”. Per the Senate Armed Services Committee that includes failing to meet cyber requirements, failing to flow down requirements to subcontractors, and submission of false claims (cyber). Add this one to the growing pile of evidence that the government really, really wants contractors to take cybersecurity seriously. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Memo: https://dodcio.defense.gov/cmmc/Resources-Documentation/ Senate NDAA: https://www.congress.gov/bill/119th-congress/senate-bill/2296/text

Watch full webinar here: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here The start of CMMC phase 1 is just around the corner. Starting on November 10th, 2025, DoD contracting officers will begin inserting CMMC status requirements in new solicitations and contracts. We recently held a webinar on the CMMC final rule to get people up to speed so this week we're bringing you our key takeaways. If you want all the details, the webinar is available on demand (registration link is in the show notes). Find out where you are on your CMMC journey here: https://www.summit7.us/pathfinder

September has come to a close and despite all the moving parts, name changes, and other potential roadblocks, the CMMC program is humming along. Assessments are being conducted at a blazing pace, the AB staff is growing, and people are still not sure if they should identify as an ESP or CSP.On this week's show, we dig into the September Cyber AB Town Hall and break down all the important details you need to know! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

DFARS clause 252.204-7021 goes into effect on November 10th, 2025, but there's more under the hood than just the text of the contract clause. Contracting officers have an entire set of procedures they must follow that dictate when and if the 7021 clause should be included in a defense contract at all. In this episode we're looking at the other side of the coin to the infamous CMMC DFARS clause. Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874 Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of DFARS 7008: https://youtu.be/vgrRGIWboKc?si=chKYMNRUea9eqpn- DFARS 7012: https://youtu.be/cy4e28YAkXU?si=OO3IEXYvfGqZQ3op DFARS 7019: https://youtu.be/7gW_82Cus7Y?si=IT2ORlBlZELxxbdu DFARS 7020: https://youtu.be/D4JLkfvB-Ws?si=-hMhIq6dJLxu1NU4 DFARS 7025: https://youtu.be/LtJK-CHuyp8?si=A6WoUGBEEgVxp5Jx DFARS 7009: https://youtu.be/kfecRRrd41w?si=PNXrbcvRLHc5GoUg 32 CFR 170 Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule?_gl=1*1qpc6eg*_up*MQ..*_gs*MQ..

Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874 The regulation that finalizes CMMC guidance for DoD contracting officers and program managers officially goes into effect on November 10th, 2025. The highlight of the regulation is the final text of DFARS clause 252.204-7021 which tells contractors which CMMC level they need to achieve in order to take award of a contract. But the regulation also created DFARS provision 252.204-7025 which officially notifies offerors of the requirements contained in the 7021 clause and it's only three paragraphs long! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of

Register for the upcoming webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here It's official: CMMC Phase 1 begins on November 10th, 2025 when the 48 CFR CMMC final rule goes into effect. After that point all new Department of Defense/War contracts will contain some level of CMMC requirement. But just when things seem certain, people are wondering about the recent class deviation regarding DFARS clause 252.204-7021. Is the use of the CMMC clause actually suspended? Spoiler: no, not even close. Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874 Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of Aug Class Deviation: https://www.acq.osd.mil/dpap/policy/policyvault/USA001756-25-DPCAP.pdf

A lot of defense contractors are betting that the DoD will only require CMMC Level 2 self-assessments during the first 12 months of CMMC (“Phase 1”). Since December 2024 there have been three official policies outlining what can be required in Phase 1 and none of them prohibit Level 2 certification assessments. Instead, every policy we can find reinforces the idea that many companies will be required to achieve CMMC Level 2 certification in Phase 1. In this episode we walk through all 3 policies so you can decide for yourself if that's a risk you want to take with your business. Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 32 CFR 170.3(e): https://www.ecfr.gov/current/title-32/part-170#p-170.3(e) The January Memo (PDF): https://dodprocurementtoolbox.com/uploads/DOPSR_Cleared_OSD_Memo_CMMC_Implementation_Policy_d26075de0f.pdf The July Memo (PDF): https://dodprocurementtoolbox.com/uploads/PTDO_Do_D_CIO_Memo_Resources_for_CMMC_Implemtation_dtd_20250728_25_T_2704_cleared_20250807_e53aa02e78.pdf

An industry event for DoD Contractors & Higher Education Institutions: https://www.summit7.us/secure-the-dib-2025 Lockheed Martin wants their suppliers to know two things. First, suppliers should be fully and confidently compliant with existing DFARS cybersecurity requirements. Second, suppliers should be fully transitioned to the “Cybersecurity Compliance and Risk Assessment” tool. All of this before CMMC ever shows up in contracts. This shouldn't come as a surprise to anyone because this is the 6th CMMC memo from Lockheed in the last 18 months. This week we take a look at each one to see where things are headed (hint: they all say the same thing). Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Blog: https://www.summit7.us/blog/lockheed-martin-pushes-suppliers-toward-urgent-cybersecurity-compliance Lockheed Memo: https://www.lockheedmartin.com/en-us/suppliers/news/features/2025/cybersecurity-program-rule.html Memo Recap: https://youtu.be/IKpH2F259J8?si=qmCyo4Mi57UvMx0g DFARS 7012: https://youtu.be/cy4e28YAkXU?si=RJwhoS6NrZJgo9Xj DFARS 7012 Class Deviation: https://youtu.be/voziZRAMvv4?si=Pm3mtgR338PE3B7b DFARS 7020: https://youtu.be/D4JLkfvB-Ws?si=aa45Tr3_UhtbtH4t