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The DoD's Own Cyber Monday: Defense Department Releases CMMC Assessment Guides

Client Alert | 1 min read | 12.09.20

Fresh off the heels of the DFARS Interim Rule, the Department of Defense (DoD) released Assessment Guides for Levels 1 - 3 of the Cybersecurity Maturity Model Certification (CMMC). These Guides will be used by Certified Assessors to determine whether contractors have satisfied the practices and processes required to attain CMMC certifications at the level needed to be awarded future DoD contracts. These new assessment procedures, which DoD calls “authoritative,” are leveraged from NIST SP 800-171A, the NIST guidance used to assess compliance with NIST SP 800-171. 

A notable inclusion in the Levels 2 – 3 Guide is the assessment criteria used to evaluate a contractor’s implementation of processes for each of the 17 CMMC Domains. Under the CMMC, the DoD has stated that contractors will not be certified at CMMC Levels 2 and above if the contractor has not satisfied both the technical practices and process maturity for the desired level.

These Guides will provide useful insights as contractors prepare for the DoD’s phased implementation of CMMC requirements into all DoD contracts over the next 5 years. 

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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....