Enhancements to Cybersecurity Requirements for DoD Contractors

What Federal Contractors Need to Know about the CMMC 2.0 Update 


As cybersecurity threats continue to evolve, the U.S. Department of Defense (DoD) is enhancing its cybersecurity requirements with the introduction of CMMC 2.0. For businesses aiming to secure and maintain contracts with the federal government, understanding and adapting to these changes is crucial. Although first announced in November 2021, the CMMC 2.0 now has an expected release in the first quarter of 2025. Thus, it’s imperative federal contractors begin the compliance process. Here’s a breakdown of the CMMC 2.0 updates and what they mean for your federal business.

What is CMMC 2.0?

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is an updated framework that streamlines the original CMMC model to improve cybersecurity practices within the Defense Industrial Base (DIB). CMMC 2.0 aims to protect sensitive information, ensure that contractors and subcontractors are meeting the DoD’s cybersecurity requirements, and ensure the integrity of federal contracts through a simplified and more flexible approach.

Key Updates to the CMMC

  1. Fewer Maturity Levels: CMMC 2.0 reduces the original five levels to three, making it easier for organizations to understand and implement necessary security controls for their level.
    • Level 1: Foundational – Basic Cyber Hygiene, applicable to companies handling Federal Contract Information (FCI) and includes an annual self-assessment.
    • Level 2: Advanced – Aligned with NIST SP 800-171, focused on protecting Controlled Unclassified Information (CUI) with triennial third-party assessments for critical national security information, with annual self-assessments for other information.
    • Level 3: Expert – Aligned with a subset of NIST SP 800-172 requirements for the highest level of protection with triennial government-led assessments.
  2. Alignment with NIST Standards: CMMC 2.0 aligns more closely with existing NIST standards, particularly NIST SP 800-171 and NIST SP 800-172, ensuring consistency and reducing redundancy in cybersecurity requirements.
  3. Flexibility in Implementation: The new model allows for the adoption of Plan of Action and Milestones (POA&Ms), enabling organizations to prioritize and address cybersecurity gaps over time rather than achieving full compliance immediately. This flexibility is intended to make it easier for companies to achieve and maintain the necessary cybersecurity standards.
  4. Cost Efficiency: The new model aims to reduce costs for small and medium-sized businesses by allowing self-assessments and reducing the frequency of third-party audits for non-critical information.

What the CMMC 2.0 Updates Mean for Your Business

  • Simplified Compliance: The streamlined levels and closer alignment with NIST standards mean a more straightforward path to compliance. Businesses need to understand the specific requirements of their relevant CMMC level and prepare accordingly.
  • Strategic Investment in Cybersecurity: While CMMC 2.0 reduces some burdens, businesses still need to invest in cybersecurity measures and training. This investment is critical for compliance and for protecting sensitive information. Demonstrating robust cybersecurity practices can increase your appeal to the DoD and other federal agencies.
  • Continuous Improvement: Compliance with CMMC 2.0 is not a one-time effort. Businesses must continuously monitor and improve their cybersecurity practices to maintain certification and adapt to emerging threats.

Next Steps for Federal DoD Contractors

Most organizations fulfilling DoD contracts will need to address CMMC requirements during requests for information and requests for proposal bids. Therefore, it’s prime time to review your existing cybersecurity practices and identify gaps in compliance with CMMC 2.0 requirements. During this review, you need to develop an implementation plan to address identified gaps, including timelines and the appropriate resource allocation.

Here’s a step-by-step list to get started:

  1. Identify and classify the data you store and/or process to support existing or new contract awards.
  2. Understand the CMMC level you will need to satisfy based on the type of data you store. Identify any gaps that could prevent you from achieving that certification level.
  3. Document all formalized processes and controls you currently have in place.
  4. Familiarize yourself with all major definitions and compliance standards included in CMMC 2.0.

While you can do much of the foundational work on your own, there are cybersecurity experts available to help you. Engage with experts specializing in CMMC compcliance to streamline the certification process and ensure you meet all necessary requirements.


CMMC 2.0 represents a significant shift in how federal DoD contractors must approach cybersecurity. By understanding and adapting to these changes, businesses can achieve compliance and enhance their overall security posture. Start preparing now to ensure your organization is ready for the new era of federal cybersecurity standards.

For more insights on navigating the CMMC 2.0 updates, contact our team at Phoenix Cyber.