DoD Previews New Third-Party Cyber Certification Requirements
Client Alert | 1 min read | 06.17.19
The Department of Defense is moving closer to a third-party certification to ensure compliance with its standard cybersecurity requirements – what is being called the “Cybersecurity Maturity Model Certification” (CMMC). While still in the early stages of development, the CMMC would likely require all contractors subject to DFARS 252.204-7012 to obtain a certification issued by an independent third party stating that the contractor has sufficiently implemented its required cybersecurity controls. Holding this certification would be a “go/no-go” condition to compete for relevant DoD work. Although NIST SP 800-171 is the default cybersecurity standard currently required under -7012, DoD is also exploring the creation of a new standard that would govern the certification. DoD is projecting that the CMMC will start appearing in solicitations as early as Fall 2020, but much work remains to be done – including potential revisions to -7012 – and will no doubt be informed by extensive industry engagement.
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Insights
Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.
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