The recent pause impacting the rollout of Cybersecurity Maturity Model Certification (CMMC) Phase II has understandably sparked inquiries within the Defense Industrial Base (DIB). Despite adversaries targeting defense contractors, supply chains, and critical technology providers, federal cybersecurity standards remain in place. Organizations that delay readiness efforts may inadvertently create gaps in areas such as: Access controls Privileged account management Multifactor authentication Data protection Audit logging Asset visibility Security documentation Evidence collection These are not just compliance concerns; they are essential security capabilities.
Supply chain visibility is particularly challenging during periods of regulatory uncertainty, as prime contractors typically possess strong insight into their own security posture compared to subcontractors and external suppliers who often lack significant visibility into how information is handled.
Organizations should prioritize reassessing supplier security expectations, reviewing subcontractor handling requirements, validating data-sharing processes, clarifying responsibility boundaries, and improving third-party visibility to prevent unnecessary friction and risk during assessments. Instead, they should focus on preserving momentum with practical actions: - Continue implementing NIST SP 800-171 controls - Maintain Plans of Action and Milestones (POA&Ms) - Update system security documentation - Collect and organize evidence - Conduct periodic internal assessments - Review access-control processes - Improve incident response readiness - Track changes to protected environments The goal should be to reduce future assessment effort, not create additional work later.
