The Next Chapter in Defense Cybersecurity: An Analysis of CMMC

Chuck Brooks / Brooks Consulting International

Home Cybersecurity The Next Chapter in Defense Cybersecurity: An Analysis of CMMC

By Chuck Brooks, president of Brooks Consulting International

The Department of Defense’s Cybersecurity Maturity Model Certification is more than a compliance checklist. It is, in my view, a strategic transformation designed to strengthen the entire defense industrial base against today’s and tomorrow’s cyber adversaries.

What makes CMMC significant is that it moves the needle from self-attestation—where contractors could simply claim readiness—to verified compliance that demands evidence of implemented security practices. This transition is not only necessary, it is long overdue.

Beyond Compliance: Elevating the Defense Supply Chain

CMMC reflects a recognition that cybersecurity is national security. Every prime contractor, subcontractor and supplier in the DIB is a potential attack vector. Malicious actors—especially nation-states—are not just stealing data; they are strategically undermining U.S. innovation, military readiness and economic strength.

In my analysis, CMMC represents an effort to standardize resilience across a highly diverse ecosystem of suppliers. By mandating common baselines, it creates a level of assurance that sensitive data—ranging from routine procurement records to highly sensitive controlled unclassified information, or CUI—is protected wherever it resides.

A Tiered, Risk-Based Evolution

One of the strengths of CMMC 2.0 is its tiered, risk-based model, aligned with NIST standards.

Level 1 (Foundational) ensures contractors with access to federal contract information, or FCI, meet basic hygiene—17 practices aligned with FAR 52.204-21.
Level 2 (Advanced) maps to NIST SP 800-171, requiring 110 practices for companies managing CUI. Some organizations can self-assess, but many must undergo third-party assessments—C3PAO—every three years.
Level 3 (Expert), tied to NIST SP 800-172, is reserved for the most sensitive CUI and requires DOD-led assessments, reflecting the higher stakes of advanced persistent threats.

This structure is not static. It will evolve to reflect the changing nature of threats, something I often emphasize: compliance must be a living framework, not a one-time exercise.

Why CMMC Matters for Small and Medium Businesses

SMBs in the DIB are often the most vulnerable yet indispensable players. They provide specialized innovation but lack the deep resources of primes. CMMC gives these companies both a mandate and a roadmap to improve resilience. While compliance will involve costs and effort, the long-term payoff is a healthier, more trusted supply chain where every link is hardened against attack.

The Cultural Shift: Accountability and Shared Security

CMMC is more than technical requirements—it is about changing culture. It enforces accountability not just at the enterprise level but across the entire supply chain.

Building a culture of cybersecurity requires leadership buy-in, continuous training and integration of security into every business process. By holding all contractors to the same high bar, CMMC is a catalyst for cultural change in how the defense community approaches cybersecurity.

Adapting to an Evolving Threat Landscape

Modern cyber adversaries are organized, well-resourced and increasingly AI-driven. They exploit automation, machine learning and stealth tactics to bypass defenses.

CMMC is a forward-leaning response. By rooting requirements in NIST’s proven frameworks and insisting on verified controls, it ensures that the defense ecosystem is prepared not just for yesterday’s phishing campaigns, but for tomorrow’s AI-enabled attacks.

The CMMC Timeline and Contractor Action Steps

Date & Phase	CMMC Requirement	Contractor Action Steps
Dec 16, 2024 – CMMC Program Rule effective	Voluntary self-assessments and third-party assessments begin	• Conduct a gap analysis against NIST SP 800-171. • Start building a system security plan, a.k.a. SSP, and plan of action & milestones, a.k.a. POA&M. • For Level 2: consider scheduling a voluntary C3PAO assessment to demonstrate readiness early.
Nov 10, 2025 – Phase 1	CMMC begins appearing in new DOD contracts (mostly self-assessment)	• Ensure all self-assessments are logged in SPRS. • Document compliance evidence for Level 1 and low-risk Level 2 contracts. • Establish ongoing monitoring so compliance is sustainable, not a “one-off.”
Nov 10, 2026 – Phase 2	Third-party assessments, or C3PAO, required for most Level 2 contracts	• Engage a C3PAO well in advance. • Remediate any gaps identified in voluntary or internal audits. • Build a repeatable compliance lifecycle with continuous monitoring and internal audits.
Nov 10, 2027 – Phase 3	DOD-led Level 3 assessments introduced	• If handling critical CUI, align with NIST SP 800-172. • Harden defenses against advanced persistent threats, or APTs. • Incorporate advanced practices such as threat-hunting, incident response playbooks and red teaming.
Nov 10, 2028 – Phase 4 (Full Implementation)	CMMC fully enforced across all new DOD contracts	• Maintain full compliance. • Treat CMMC as part of corporate governance. • Integrate cybersecurity into supply chain management, ensuring subcontractors also comply.

Why Is CMMC Important?

In my assessment, CMMC is not just another compliance burden—it is a strategic evolution in how we secure the defense supply chain. Contractors who prepare now will not only be contract-eligible but will also gain a competitive advantage as trusted, resilient partners.

The key is action: don’t wait for 2025 or 2026. Start with a gap analysis today, engage stakeholders, and embed security into the culture of your organization.

As I often emphasize, adversaries innovate constantly—so must we. CMMC is the framework to ensure that innovation is defended, and defense is verified.