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 and Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 7 min read | 10.29.26
On 8 October 2026, Crowell & Moring, King's College London, and the Competition Law Center at George Washington University co-hosted the 7th EU Competition Law Conference at De Warande in Brussels. Mark Meador, Commissioner at the US Federal Trade Commission (FTC), delivered the opening keynote address, followed by four panels bringing together practitioners, regulators, academics, and in-house counsel to discuss the latest developments in EU, UK, and US competition law enforcement. Among other things, the panels examined algorithmic pricing; the European Commission's (Commission) new guidelines on exclusionary abuses under Article 102 TFEU (Article 102 Guidelines); the impact of dominant positions in merger reviews; and lessons from the enforcement of the Digital Markets Act (DMA) and the UK’s Digital Markets, Competition and Consumers Act.
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
Client Alert | 2 min read | 10.28.26
Debriefing to Dead Briefing: How to Avoid Dismissal by Identifying “Required” Debriefings
Client Alert | 7 min read | 10.27.26
