Immaturity of the Cybersecurity Maturity Model: Revisions Omit Higher-Level Updates
Client Alert | 1 min read | 11.13.19
Last week, the Defense Department (DoD) released Revision 0.6 to the Cybersecurity Maturity Model Certification (CMMC). Notably absent were revisions to Levels 4 – 5, which DoD promises in the next public release. While the final version of the CMMC is due in late January, Revision 0.6 updated CMMC Levels 1 – 3 by:
- Condensing the CMMC requirements;
- Modifying the practices and processes; and
- Providing clarifications and examples for CMMC Level 1 requirements.
Revision 0.6 also distilled the core requirements for Levels 1 – 3 into the following categories:
- Level 1 -- Basic cyber hygiene: Implementation of security controls in FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems;
- Level 2 -- Intermediate cyber hygiene: Implementation of select NIST SP 800-171 controls; and
- Level 3 -- Good cyber hygiene: Full implementation of NIST SP 800-171 controls.
Industry will benefit from reviewing this latest draft and preparing for DoD’s pending implementation of the CMMC.
Contacts
Partner, Crowell Global Advisors Senior Director
Insights
Client Alert | 4 min read | 09.12.25
SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal
On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.
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
Client Alert | 1 min read | 09.10.25
