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Cybersecurity Maturity Model Matures: DoD Adds New Requirements to Draft Cybersecurity Certification

Client Alert | 1 min read | 09.10.19

The Defense Department has released Revision 0.4 of its Cybersecurity Maturity Model Certification (CMMC) that, starting next year, independent auditors are to use to certify contractor compliance with DoD cybersecurity requirements.  Revision 0.4 more than doubles the number of cybersecurity controls across the CMMC’s five maturity “Levels.”  But the DoD emphasizes that it will further down-select these controls and that mature contractor processes may counteract gaps in the final controls’ implementation.  In addition to NIST SP 800-171 (the default standard under DFARS 252.204-7012), Revision 0.4 now incorporates requirements from the NIST Cybersecurity Framework, ISO 27001, and CIS Critical Security Controls, as well as from “additional DIB inputs.”  Notably missing is NIST SP 800-171B, which remains under review.

The DoD is requesting feedback on Revision 0.4 through September 25, 2019, and plans on releasing Revision 0.6 for comment in November 2019.   The final CMMC is expected in January 2020. 

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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....

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