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ARTICLE · 18 SEPTEMBER 2025

Department Of Defense Releases Long-Anticipated Final Rule Implementing The Cybersecurity Maturity Model Certification Program

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On September 9, 2025, the Department of Defense (DoD) published a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements...

United StatesGovernment, Public Sector
Rajesh De
Rajesh De
Adam S. Hickey
Adam S. Hickey
John Prairie
John Prairie
Stephen Lilley
Stephen Lilley
Veronica R. Glick
Veronica R. Glick
Kathryn Allen
Kathryn Allen
Hadassah G. Diament
Hadassah G. Diament
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On September 9, 2025, the Department of Defense (DoD) published a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements to implement the Cybersecurity Maturity Model Certification (CMMC) program.

CMMC was designed to ensure government contractor compliance with cybersecurity standards and best practices, including pertaining to access controls, software updates, authentication, physical security, and reporting of security incidents. As we explained in our last Legal Update on the topic, a prior rulemaking established the substantive cybersecurity standards of the CMMC program. This rule finalizes the integration of CMMC into the DoD acquisition process by establishing the procedural framework for assessing and verifying contractor cybersecurity practices, including implementation of requirements to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the

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