CMMC 2.0: DoD Unveils Sweeping Changes Streamlining CMMC Requirements
Client Alert | 1 min read | 11.05.21
The Department of Defense (DoD) recently announced significant changes to its Cybersecurity Maturity Model Certification (CMMC) program intended to simplify the requirements and ease the compliance burden on contractors. Unlike its predecessor, the new CMMC 2.0 moves to three compliance levels rather than five; aligns the required security controls (known as practices) with National Institute of Standards and Technology (NIST) Special Publications (SP) 800-171 and 800-172; and eliminates entirely previously required maturity processes. The changes also include a shift to self-assessments for all but contractors supporting the most sensitive programs, as well as the return of Plans of Action and Milestones (POAMs) to demonstrate compliance and achieve certification.
The new requirements are summarized below:
- CMMC Level 1, Foundational – Contractors must implement the 17 controls from NIST SP 800-171 enumerated in FAR 52.204-21 and submit an annual self-assessment to the DoD through the Supplier Performance Risk System (SPRS).
- CMMC Level 2, Advanced – Contractors must implement the 110 controls in NIST SP 800-171 and submit an annual self-assessment or, if required to handle (as yet undefined) critical national security information, a triennial independent assessment performed by a CMMC Third Party Assessment Organization (C3PAO).
- CMMC Level 3, Expert – Contractors must implement the 110 controls in NIST SP 800-171 and a subset of controls from NIST SP 800-172 before undergoing a triennial government-led assessment. The DoD, however, is still in the process of developing the requirements for this Level.
CMMC 2.0 will be implemented through the rulemaking process, which the DoD estimates could take anywhere from nine months to two years. Thereafter, the DoD will begin to incorporate CMMC 2.0 requirements into contracts. In the meantime, the DoD has suspended its CMMC pilot program and will not approve the inclusion of CMMC requirements in any forthcoming DoD solicitations.
Contacts
Partner, Crowell Global Advisors Senior Director
Insights
Client Alert | 3 min read | 09.15.25
On August 19, 2025, the U.S. Senate Committee on Finance (“Senate Finance Committee”) sent Paul Atkins, Chairman, U.S. Securities and Exchange Commission (“SEC”) a letter calling on the SEC to investigate White River Energy Corp (“White River”). In the letter, the Senate Finance Committee confirmed a criminal investigation into White River related to the sale of so-called “tribal tax credits” that according to both Congress and the IRS, do not exist. The letter further states that White River allegedly earned millions of dollars selling these credits and has not been forthcoming with investors regarding the existence of the criminal investigation. According to the Senate Finance Committee, White River has failed to file financial disclosure documents with the SEC since March 15, 2024, missing six consecutive reporting periods. The letter instructs White River to disclose the existence of the DOJ criminal tax investigation, and calls on the SEC to take action if White River fails to do so.
Client Alert | 4 min read | 09.12.25
SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal
Client Alert | 6 min read | 09.11.25
U.S. Department of Commerce Partially Relaxes Export Controls on Syria
Client Alert | 9 min read | 09.11.25
