Cybersecurity has become one of the most critical priorities for the U.S. defense supply chain. As cyber threats targeting defense contractors continue to grow, the U.S. government has introduced the CMMC program to strengthen protection of sensitive information.
A recent Government Accountability Office (GAO) report examines how the Department of Defense is implementing CMMC and what challenges could affect the program’s rollout. The report highlights the importance of cybersecurity compliance across the Defense Industrial Base (DIB) and identifies several factors that could impact the program’s success.
For defense contractors and subcontractors, understanding the implications of this report is essential for preparing for upcoming CMMC requirements and cybersecurity compliance obligations.
What Is the CMMC Program?
The Cybersecurity Maturity Model Certification CMMC program is a cybersecurity framework created by the U.S. Department of Defense to ensure that contractors properly protect sensitive government information.
Defense contractors often handle two types of sensitive data:
These types of information can be targeted by cyber attackers seeking sensitive military data, intellectual property, or technical designs. The CMMC program was created to verify that companies in the defense supply chain have implemented adequate cybersecurity controls to protect this information.
Unlike earlier compliance approaches that relied primarily on self-attestation, CMMC introduces formal certification requirements for many contractors.
If you have any questions about Controlled Unclassified Information (CUI), check out our previous blog.
Why CMMC Matters for the Defense Industrial Base
The defense industrial base includes hundreds of thousands of companies that support U.S. defense programs. These organizations range from large prime contractors to small manufacturers and service providers.
Cybersecurity vulnerabilities within this network can create significant national security risks. If one supplier has weak cybersecurity practices, attackers may exploit that weakness to access sensitive defense data.
The CMMC program is designed to strengthen cybersecurity across the entire supply chain by requiring contractors to demonstrate compliance with established security standards.
For many organizations working with the Department of Defense, CMMC certification will soon become a requirement for contract eligibility.
The Three Levels of CMMC Certification
The revised CMMC framework introduces three certification levels, each corresponding to the sensitivity of the information handled by contractors.
Level 1: Foundational Cybersecurity
Level 1 applies to companies that handle Federal Contract Information (FCI). These organizations must implement basic cybersecurity practices and perform annual self-assessments.
Level 2: Advanced Cybersecurity
Level 2 applies to companies that handle CUI. Contractors must implement cybersecurity controls aligned with NIST SP 800-171. Many organizations at this level will require assessments conducted by authorized third-party assessors.
Level 3: Expert-Level Cybersecurity
Level 3 is intended for organizations supporting critical defense programs and handling highly sensitive information. These companies must implement enhanced cybersecurity protections and undergo government-led assessments.
CMMC Implementation Timeline
The Department of Defense plans to introduce CMMC requirements gradually through a phased implementation process.
The rollout is expected to occur over approximately three years, with certification requirements appearing in contracts in stages.
Early phases will focus on basic cybersecurity self-assessments, while later phases will require formal certification for companies handling more sensitive data.
This phased approach is intended to give contractors time to prepare for the new compliance requirements.
Not sure where your organization stands with CMMC, ITAR, or federal cybersecurity requirements? The fastest way to get clarity is to talk with an expert. Book a call with our team to review your current environment, identify compliance risks, and understand what steps are required to move forward. A short conversation can help you avoid costly mistakes and focus on what matters for contract eligibility and security.
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Key Findings from the GAO Report
Potential Challenges Identified by GAO
The GAO report highlights several risks that could impact the effectiveness and rollout of the CMMC program across the Defense Industrial Base.
Limited Certification Capacity
CMMC relies on Certified Third-Party Assessment Organizations (C3PAOs) to perform Level 2 assessments. However, the current number of authorized assessors remains limited compared to the number of contractors that will require certification.
Examples of active C3PAOs include:
- KNC Consulting
- Coalfire Federal
- Kratos Defense
- A-LIGN
- Redspin
Due to high demand, many C3PAOs are already experiencing scheduling backlogs. In some cases, organizations like KNC have been reported to be 4 to 6 weeks out or more for assessment availability, and timelines are expected to increase as more contractors enter the certification pipeline.
This creates a bottleneck that could delay contract eligibility for companies that are not prepared early.
Compliance Costs for Contractors
Achieving CMMC compliance requires investment in both technology and processes.
Costs may include:
- Implementing NIST SP 800-171 security controls
- Upgrading IT infrastructure and security tools
- Hiring cybersecurity personnel or consultants
- Preparing documentation such as SSPs and POA&Ms
- Paying for third-party assessments
For small and mid-sized contractors, these costs can be significant and may impact their ability to compete for or maintain DoD contracts.
Evolving Cybersecurity Standards
CMMC is closely aligned with NIST SP 800-171, which continues to evolve alongside emerging cyber threats.
As requirements change, contractors must continuously update:
- Security controls
- Policies and procedures
- System configurations
- Risk management practices
Organizations that treat compliance as a one-time effort may fall out of alignment as standards evolve.
Why This Matters
These challenges highlight a key reality:
Companies that wait too long to prepare may face delays, increased costs, or loss of contract opportunities.
Early preparation, proper scoping, and working with experienced partners can significantly reduce these risks.
Potential Challenges Identified by GAO
One key finding is that the Department of Defense has developed multiple planning documents and implementation strategies to support the rollout of CMMC.
These documents are not housed in a single location. Instead, they are distributed across official DoD and federal resources, including:
- The DoD Chief Information Officer (CIO) website
- CMMC program guidance and rulemaking publications
- Federal Register notices related to the CMMC rule
- NIST publications such as NIST SP 800-171 and supporting guidance
These planning documents outline:
- Program structure and requirements
- Roles and responsibilities across the DoD
- Certification processes and assessment expectations
- Timelines for implementation across the defense supply chain
While much of this information is publicly available, it is spread across multiple sources. This can make it difficult for contractors to fully understand the complete CMMC framework without consolidating guidance from several locations.
Limited Certification Capacity
CMMC relies heavily on third-party organizations to conduct cybersecurity assessments. If the number of qualified assessors is insufficient, contractors may face delays in obtaining certification.
Compliance Costs for Contractors
Implementing cybersecurity controls and completing certification assessments may be costly, particularly for smaller companies. These costs could discourage some suppliers from participating in defense contracts.
Evolving Cybersecurity Standards
Cybersecurity frameworks such as NIST standards continue to evolve. The CMMC program must remain aligned with these evolving requirements to stay effective.
Resources Available to Help Contractors Prepare
To support implementation of CMMC, the Department of Defense has introduced several programs designed to help contractors improve their cybersecurity posture.
These initiatives include:
- Cybersecurity training for the defense acquisition workforce
- Programs designed to assist small businesses with cybersecurity improvements
- Collaboration with industry organizations to build the certification ecosystem
These efforts are intended to ensure that both government personnel and contractors are prepared for the transition to CMMC certification.
What Defense Contractors Should Do Now
For companies working in the defense supply chain, the rollout of CMMC means that cybersecurity compliance will become increasingly important for maintaining eligibility for government contracts.
Organizations should begin preparing by:
- Assessing their current cybersecurity practices
- Determining whether they handle FCI or CUI
- Reviewing NIST SP 800-171 requirements
- Implementing security controls where gaps exist
- Monitoring updates related to CMMC implementation timelines
Early preparation can help contractors avoid delays and maintain their ability to compete for defense contracts.
The CMMC program represents a major shift in how the Department of Defense approaches cybersecurity within the defense industrial base.
By introducing certification requirements and strengthening oversight of contractor cybersecurity practices, the program aims to reduce vulnerabilities across the defense supply chain.
The recent GAO report shows that significant progress has been made, but it also emphasizes the need to address external risks that could affect the program’s rollout.
For defense contractors and subcontractors alike, understanding the evolving CMMC cybersecurity requirements will be essential for staying compliant and continuing to support defense programs.
Not sure if your organization is ready for CMMC Level 2?
Download our CMMC Level 2 Audit Checklist to see exactly what assessors look for during an evaluation. This checklist helps defense contractors understand required controls, documentation expectations, and common gaps that can delay certification. Use it to evaluate your current environment, identify risks early, and prepare your organization before CMMC requirements impact your ability to win or maintain Department of War contracts.
Brea Networks is a cybersecurity and compliance focused IT partner dedicated to supporting Defense Industrial Base (DIB) contractors. We help organizations understand and implement the security requirements outlined in FAR 52.204-21, DFARS 252.204-7012, ITAR/EAR, and the CMMC framework; from Level 1 self-assessments to Level 2 and Level 3 readiness.
Our team works alongside contractors to strengthen system security, define assessment scope, prepare documentation such as System Security Plans (SSPs) and POA&Ms, and build sustainable cybersecurity programs that protect FCI and CUI. Whether you are preparing for a self-assessment, a C3PAO certification, or simply improving your security posture, Brea Networks provides practical guidance and technical expertise to help you move forward with confidence.
Brea Networks
Telephone: 714-592-0063
451 W Lambert Rd Ste 214
Brea, CA 92821
