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ARTICLE · 12 FEBRUARY 2020

CMMC Moves Toward Reality

DoD has long believed that contractors' compliance with the DFARS clause has been uneven, posing a substantial security risk.

United StatesGovernment, Public Sector

The U.S. Department of Defense (DoD) released version 1.0 of its Cybersecurity Maturity Model Certification (known as CMMC) on Jan. 31, 2020. The CMMC model draws heavily on the National Institute for Standards and Technology's (NIST) Special Publication (SP) No. 800-171, as well as other cyber protection standards. Once DoD's rollout of the CMMC program is complete, contractors will need to have third-party certifications in order to be awarded DoD contracts.

While DoD implements all the elements of CMMC, DoD contractors will still need to comply with the existing DoD cybersecurity regulations, which went into effect on Jan. 1, 2017. These regulations require covered DoD contractors to: 1) comply with the NIST SP 800-171 cybersecurity standards; 2) report cyber incidents to DoD within 72 hours of discovery; 3) investigate cyber incursions while preserving affected media/data for 90 days and, if applicable, submit malicious software (discovered in connection with a

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