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CMMC 2.0: Urgent Compliance Deadlines for Small DoD Contractors

Image depicting deadlines for CMMC compliance for small businesses
Time to Embrace the CMMC Suck
posted by Rich Delaney, CSO

September 29, 2023

The Intersection of CMMC and NIST 800-171 Cybersecurity Framework

CMMC is fundamentally based on the NIST 800-171 standard. If you're already compliant with NIST 800-171, you're on the right track, but CMMC adds a certification layer.

Why CMMC Matters to You

CMMC is a mandatory certification for any business in or doing business with the Defense Industrial Base (DIB). Non-compliance could mean losing out on lucrative DoD contracts or a complete inability to continue to do business if you're focused on selling to the DIB.

Deadlines and Consequences

The expected final date for compliance is yet to be confirmed but is likely to be October 2025. While there are no direct monetary penalties for non-compliance, failure to comply could result in the loss of DoD contracts. The DoD indicates that achieving compliance can take anywhere from 9-24 months.

How Long Does it Take to Comply with CMMC 2.0?

For companies with a mature cybersecurity framework, it takes, on average, 12-18 months to comply. If you're just starting, it will take even longer.

Start Now, Not Later

This is not new news. The DoD has been announcing this for several years. Don't wait until October 2025 to start; the time to act is now.

DCS Clients Are Already Ahead of the Game

Our current clients utilizing our advanced cybersecurity stack and fully managed services are already well-positioned for CMMC compliance. DCS has existing relationships with C3PAOs who can ultimately certify you if required. However, achieving full compliance will require significant cooperation and buy-in from owners and senior management.

A Roadmap to CMMC 2.0 Compliance

  1. Conduct a Cybersecurity Audit: Resources like the CMMC Small Business Resource Center offer valuable tools for self-assessment.

  2. Craft a Compliance Strategy: This should include a timeline and budget allocation.

  3. Execute Your Plan: Implement the cybersecurity controls as per your plan.

  4. Seek Third-Party Validation: Engage a CMMC Third Party Assessor Organization (C3PAO) to evaluate your cybersecurity measures.

In Conclusion - Embrace the Suck!

To borrow a military colloquialism popularized by the US Marines, "Embrace the Suck."

Let's be real; we're not going to use some fluffy marketing BS: Achieving CMMC 2.0 compliance will not be a walk in the park, especially for small businesses already juggling multiple priorities. The process is complex, time-consuming, and, yes, it can be frustrating. But here's the kicker—you have little choice but to embrace it.

The Real Challenge: Changing Company Culture

The hardest part isn't just the technical adjustments; it's transforming your company culture into one that prioritizes cybersecurity and compliance. This monumental shift takes more than a year or even two in some small businesses. Why? Because it requires genuine buy-in from the owners and senior management.  

Gone are the days of "do as I say, not as I do" hypocrisy. If you, as a leader, don't fully embrace a culture of cybersecurity, you can't expect your employees to do so either.  Start now, take it one inch by inch, and move the ball forward daily, and it eventually gets done.

Non-compliance isn't an option if you want to continue doing business with the DoD or its contractors. The risks of ignoring these regulations far outweigh the challenges of compliance. You could lose existing contracts and be barred from future opportunities, effectively closing the door on a significant revenue stream.

So, while the journey to CMMC 2.0 compliance may feel like an uphill battle, you can't afford to sidestep it.

The good news? You don't have to go it alone. DCS clients already have a massive headstart if you're using our advanced cybersecurity stack we call DCS Cybershield.

DCS has existing relationships with C3PAOs and offers advanced cybersecurity stacks and fully managed services to help you navigate this complex landscape.

"Embracing the suck" means acknowledging the difficulties but taking proactive steps to overcome them. And remember, the sooner you start, the easier it will be to meet those looming deadlines.