In the defense industrial base, the definition of "quality" has shifted. For decades, your reputation was built on the precision of your machining and the reliability of your delivery. In 2026, those factors are still vital, but they are no longer enough to win the contract.
The Department of Defense (DoD) has effectively digitized the vetting process. With CMMC Phase 1 fully integrated and Phase 2 (C3PAO assessments) becoming a mandatory condition of award as of November 2026, your IT infrastructure is now an audited part of your manufacturing capability. If your IT setup doesn't meet the mark, you are effectively "invisible" to DoD procurement officers—or worse, a liability to the Prime contractors you support.
As a vCISO, I see many well-run manufacturing firms unknowingly harboring technical "red flags" that trigger immediate disqualification during the bid process. Here are the five most critical red flags in your IT environment that could end your defense legacy before 2026.
Red Flag 1: The "Where is the Data?" Blind Spot
Red Flag 2: Universal Access and "Shared" Admin Accounts
Red Flag 3: The "If It Isn't Written, It Doesn't Exist" Rule
Red Flag 4: "Shadow IT" and Personal Devices
Red Flag 5: A Reactive "Wait and See" Mentality
Frequently Asked Questions About CMMC Compliance
Red Flag 1: The "Where is the Data?" Blind Spot
Many CEOs believe their data is "safe" because it’s on a local server. However, CMMC compliance requires you to prove exactly how Controlled Unclassified Information (CUI) flows through your company. If you cannot produce a "Data Flow Diagram" that tracks an engineering drawing from the moment it leaves a Prime contractor’s portal to the moment it hits your CNC machines, you have a massive audit risk.
A lack of data visibility often leads to "scope creep." If you don't know where CUI is, you have to treat your entire network as if it contains top-secret data. This makes your IT costs skyrocket.
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The Fix: Conduct a data discovery audit. Identify exactly where CUI lives—and more importantly, where it shouldn't be.
Red Flag 2: Universal Access and "Shared" Admin Accounts
In many machine shops, it’s common for multiple operators to share a single computer terminal with a generic login. For a defense contractor in 2026, this is an automatic audit failure. CMMC requires "individual accountability." Every person who touches a system containing CUI must have a unique, tracked identity.
Furthermore, if your internal IT staff or "computer guy" is still using a single administrator account for everything, you are exposed. High-level access should be strictly limited and protected by Multi-Factor Authentication (MFA)—no exceptions.
- The Fix: Implement a "Least Privilege" model. Give employees access only to what they need for their specific job, and enforce MFA for every single login.
Red Flag 3: The "If It Isn't Written, It Doesn't Exist" Rule
I often meet CEOs who tell me, "Oh, we do that security step every Friday." When I ask to see the policy or the log proving it happened, they have nothing. In a C3PAO assessment, verbal promises have zero value.
If your company lacks a formal System Security Plan (SSP), you are disqualified. The SSP is a living document that describes every security control you have in place. Without it, you cannot submit a score to the Supplier Performance Risk System (SPRS), and without an SPRS score, you cannot receive a contract award.
- The Fix: Treat your security documentation like your ISO 9001 certifications. It must be documented, repeatable, and audited.
Red Flag 4: "Shadow IT" and Personal Devices
In an era of remote work and hybrid offices, many employees have fallen into the habit of checking work email on personal phones or saving CAD files to a personal Dropbox to "work from home." For defense contractors, this is a catastrophic red flag.
If CUI touches a personal device that isn't managed by your company, that device is now part of the audit scope. Most personal devices fail the encryption and security requirements of NIST 800-171, meaning one employee’s "shortcut" could disqualify your entire firm.
- The Fix: Implement strict "No Personal Device" policies for CUI and use Mobile Device Management (MDM) tools to secure company-issued hardware.
Red Flag 5: A Reactive "Wait and See" Mentality
The biggest red flag isn't a piece of hardware; it’s a business strategy. Many CEOs are waiting for a specific "audit notice" before they invest in CMMC readiness. However, the DoD has made it clear: the certification must be in place at the time of award.
Because the roadmap to Level 2 certification typically takes 6 to 12 months, "waiting" is effectively a decision to stop bidding on defense work. If you aren't actively closing gaps today, you are signaling to Prime contractors that you are a high-risk partner who may not be around in 2027.
- The Fix: Begin a formal Gap Analysis immediately to determine your baseline and build a realistic budget for remediation.
Expert Insight: "Compliance is not a destination; it is a continuous state of readiness. In the defense sector, your cybersecurity posture is now as important as your production capacity." — Jim Ambrosini, vCISO
Frequently Asked Questions About CMMC Compliance
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What is the primary keyword for my SPRS score?
The primary driver for your contract eligibility is your NIST 800-171 assessment score, which is uploaded to the Supplier Performance Risk System (SPRS). While "CMMC Compliance" is the certification you are aiming for, your SPRS score is the current metric the DoD uses to vet your company’s reliability. A perfect score is 110, and any score below that requires a formal Plan of Action and Milestones (POA&M) to show how you will reach full compliance.
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How does CMMC Phase 1 affect my current manufacturing bids?
As of late 2025, Phase 1 is in effect, meaning the DoD can include CMMC Level 1 or Level 2 "Self-Assessment" requirements in any new solicitation. If you are bidding on work today, you must be able to verify—under penalty of the False Claims Act—that you are meeting the security requirements listed in your contract. Failure to do so can result in "stop-work" orders or legal action.
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Is NIST 800-171 the same as CMMC Level 2?
Essentially, yes. CMMC Level 2 is built directly upon the 110 security controls found in NIST 800-171. The main difference is that under CMMC, you can no longer simply "self-certify" that you are following these rules. You must have an independent auditor (a C3PAO) verify your implementation and grant you a formal certification that lasts for three years.
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What are the most common "technical" reasons for failing a CMMC audit?
The most common failures usually involve FIPS-validated encryption and Multi-Factor Authentication (MFA). Many manufacturers use standard encryption that isn't government-certified, or they have "gaps" in their MFA—such as not requiring it for local server logins or shop-floor terminals. These are "weighted" heavily in the scoring system and can quickly tank your eligibility.
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How much time should a CEO budget for a CMMC Level 2 transition?
For a mid-sized manufacturer, the transition usually takes 9 to 14 months. This includes the initial gap analysis, the remediation phase (upgrading hardware and software), the documentation phase (writing policies), and the final "mock audit" to ensure you are ready for the actual C3PAO assessment. Starting late is the primary reason companies lose their "Preferred Supplier" status.
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Does CMMC compliance apply to my non-defense commercial work?
Technically, no. CMMC only applies to systems that handle DoD information. However, if your commercial and defense work happen on the same network, the entire network must be compliant. To save money, many CEOs choose to "enclave" their defense work, creating a separate, highly secure sub-network just for DoD contracts, which keeps the rest of the business out of the audit scope.
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Who is responsible for signing the CMMC affirmation?
Under the new rules, a Senior Company Official (typically the CEO, COO, or CFO) must sign an annual affirmation stating that the company is maintaining its cybersecurity posture. This shift ensures that compliance is a leadership responsibility, not just an "IT problem." This signature carries significant legal weight and should only be provided after a thorough internal review.
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What is a C3PAO and how do I find one?
A C3PAO is a Certified Third-Party Assessment Organization. These are the only entities authorized by the CMMC Accreditation Body (Cyber AB) to conduct Level 2 audits. Because there is a limited number of these organizations and thousands of defense contractors, there is currently a significant backlog. It is recommended to engage with a vCISO early to ensure you are "audit-ready" before you book your C3PAO window.
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Can I use a "Plan of Action and Milestones" (POA&M) to win a bid?
Under CMMC 2.0, the use of POA&Ms is strictly limited. You cannot have a POA&M for the most critical controls (the "5-point" controls), and any remaining gaps must be remediated within 180 days of the assessment. This is a major shift from previous years where companies could operate with open POA&Ms for years. Now, "close enough" is no longer acceptable.
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What happens if we lose our CMMC eligibility?
The consequences are immediate and financial. You will be unable to win new DoD contracts, and your Prime contractors (like Lockheed Martin, Boeing, or Northrop Grumman) will be forced to move their business to a compliant supplier to protect their own certification. For many mid-sized aerospace firms, losing DoD eligibility is a "business-ending" event.





