In the defense sector, regulatory compliance is no longer just a box to check—it is the license to operate.
Recently, I had the privilege of hosting an episode of the ISC2 New Jersey Chapter podcast, Unencrypted Chatter, alongside my colleague Wesley Reinhart, CompassMSP’s CMMC Program Director. Wes lives and breathes compliance, specifically helping clients navigate the labyrinth of ITAR, NIST, and the Cybersecurity Maturity Model Certification (CMMC).
Our conversation cut through the noise regarding the Department of Defense's (DoD) Final Rule. The takeaway is stark: The "wait and see" era is over.
If you are a business leader or IT Director in the Defense Industrial Base (DIB), the timeline has shifted from "eventual" to "imminent." Below, I’ve synthesized the critical takeaways from our discussion, outlining why November 2025 is your new hard stop and how to turn this regulatory burden into a competitive advantage.
The Executive Risk: Why the C-Suite Must Pay Attention
The Scoping Strategy: Don't Boil the Ocean
The Timeline Bottleneck: Why You Must Start Now
Turn Compliance into a Competitive Differentiator
For years, contractors have self-attested to their compliance with NIST 800-171. However, the DoD found that self-attestation often meant "wishful thinking" rather than actual security.
As Wes explained during the podcast, the game changes officially in November 2025. Starting then, no new DoD contracts or modified task orders on existing contracts will be awarded to organizations handling Controlled Unclassified Information (CUI) unless they have achieved CMMC Level 2 Certification.
This applies to everyone. Whether you are a prime contractor like Lockheed Martin or a ten-person machine shop making specialized bolts, if you handle CUI, the standard is the standard.
Even if you don’t hold a direct contract with the DoD, you are not immune. Prime contractors are required to ensure their entire supply chain is secure. We are already seeing Primes demanding third-party assessments from their subcontractors before the official DoD mandate kicks in to protect their own contract eligibility.
One of the most critical points we discussed is the shift in liability. CMMC is not just an IT problem; it is a boardroom risk.
Under the new rules, a senior company official (CEO, COO, etc.) must sign off on the assessment, putting their name on the line to attest that the cybersecurity controls are functional. This opens the door to significant legal exposure under the False Claims Act.
We are seeing a rise in whistleblower suits where employees report their own companies for falsifying their Supplier Performance Risk System (SPRS) scores. If you attest to a perfect score of 110 but are found to be negligent, the consequences go beyond losing a contract—they can include massive fines and punitive damages against the organization.
A common panic reaction we see is companies trying to secure everything. Wes outlined a much more strategic approach during our talk: Scoping and Enclaves.
If you try to bring your entire enterprise network up to CMMC Level 2 standards, the cost and operational friction can be crippling. Instead, we often recommend an Enclave Solution. This involves creating a segmented, highly secure environment specifically for CUI handling, while leaving the rest of the business network to operate under standard commercial best practices.
The CompassMSP Methodology:
If you take nothing else away from this article, let it be this: You cannot pull this off in three months.
Wes highlighted a logistical reality that many leaders overlook. Even if you started your journey today, remediation—writing policies, implementing Multi-Factor Authentication (MFA), setting up change management, and gathering evidence—can take 6 to 12 months.
Once you are ready, you cannot simply walk into an exam. You must schedule an assessment with a C3PAO (Certified Third-Party Assessor Organization). Currently, the waitlists for these assessors are stretching 6 to 8 months.
If you do the math, starting today puts you roughly 18 to 24 months away from certification. With the November 2025 deadline passed, you need to move with a sense of urgency.
We ended the podcast on a positive note. Yes, this is a burden, but it is also a massive opportunity.
The defense supply chain is going to shrink. Many companies will simply exit the market because they cannot or will not comply. By achieving CMMC Level 2 certification early, you position your firm as a "low-risk" partner to the Primes.
You become the preferred vendor not just because of your product quality, but because your cyber maturity safeguards their contracts. This is how you flip a cost center into a revenue driver. Your compliance becomes a true differentiator!
There is so much more nuance to this discussion, including how to handle Plans of Action and Milestones (POAMs) and the specific cultural shifts required to get staff buy-in.
I highly encourage you to watch the full episode here:
Watch the Podcast on YouTube
For a deep dive into the regulatory changes, read our full breakdown:
CMMC Compliance 2025: What’s Changing and When