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ARTICLE · 08 FEBRUARY 2024

The DoD's New Cybersecurity Requirements Are Here! But More Are Certainly To Come

Taft, Stettinius & Hollister LLP
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On Dec. 26, 2023, more than two years after announcing its plans for Cybersecurity Maturity Model Certification (CMMC) 2.0, the Department of Defense...

United StatesTechnology
Alexander Gorelik
Alexander Gorelik
Erin R. Davis
Erin R. Davis
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On Dec. 26, 2023, more than two years after announcing its plans for Cybersecurity Maturity Model Certification (CMMC) 2.0, the Department of Defense (DoD) finally unveiled its plan for changing the original CMMC requirements to its new approach, "CMMC 2.0." The new plan came in a proposed rule that will redefine how the DoD expects defense contractors and subcontractors to satisfy their cybersecurity requirements. Like the original, CMMC 2.0 still requires contractors to meet the requirements of a particular CMMC level associated with their procurement. However, it does so in a more streamlined manner using Levels 1, 2, and 3 to demonstrate escalating system maturity.

Despite its references, the proposed rule does not address "CMMC-related contractual processes." Those processes will instead be addressed in separate rulemaking as part of the DoD's DFARS Case 2019-D041, Assessing Contractor Implementation of Cybersecurity Requirements. The latest report on

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