Insights

The FAR Council recently released an updated draft of the much-anticipated “FAR CUI Rule” that would apply to contractors government-wide.

The Department of War (DoW) is immediately suspending Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which had been scheduled to take effect on November 10, 2026.

On June 25, 2026, the Federal Risk & Authorization Management Program (FedRAMP) launched its Consolidated Rules for 2026, marking a significant turning point in how the U.S. government administers security authorizations of private sector cloud offerings. The Consolidated Rules apply to all variants of the FedRAMP ecosystem, including legacy "Rev5" authorization holders, as well as future certifications under the new 20x program. Importantly, the Rules are intended in part to transition Rev5 authorizations over to 20x, with the Rev5 authorization status expected to terminate by the end of 2028. 

After years of anticipation and a series of delays, implementation of the U.S. Department of Defense’s Cyber Maturity Model Certification Program (CMMC) is rapidly approaching. Though CMMC is not expected to enter into effect until early-to- mid 2025, DOD contactors can start taking steps now to ensure a smooth transition into this new regulatory era.

U.S. colleges and universities watched closely this summer when the DOJ, in a novel move, scrutinized the cybersecurity compliance of a research lab at an academic institution.

The Department of Defense (DoD) has released the highly anticipated second final rule for the Cybersecurity Maturity Model Certification Program (CMMC), ushering in its mandatory implementation that begins on November 10. CMMC is a unified assessment model released by the DoD in response to the growing threat of cyberattacks on and data theft from the Defense Industrial Base.  This program requires every DoD contractor that handles sensitive government data to certify compliance with certain cybersecurity controls.  CMMC brings greater scrutiny to contractors’ cybersecurity compliance and greater risks associated with compliance failures. To achieve certification, contractors must prove that their organizations can meet a myriad of security control obligations, a process that can be daunting without familiarity with the policies, procedures, and practices that will be required when the program is finalized.