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ARTICLE · 22 DECEMBER 2025

US Finalizes CMMC Rule: Cybersecurity Verification Now Determines Contract Eligibility For Defense Contractors

Bass, Berry & Sims PLC
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With the CMMC rule finalized, cybersecurity in defense contracts has become more than just a technical concern; it is now a key compliance and legal requirement.

United StatesTechnology
Richard W. Arnholt
Richard W. Arnholt
Todd Overman
Todd Overman

With the CMMC rule finalized, cybersecurity in defense contracts has become more than just a technical concern; it is now a key compliance and legal requirement. Although implementation will be phased, contractors who adapt and prepare early better position themselves to compete and comply, say Richard W. Arnholt and Todd R. Overman of law firm Bass, Berry & Sims.

The final rule implementing the cybersecurity maturity model certification (CMMC) program into the Defense Federal Acquisition Regulation Supplement (DFARS) took effect just over one month ago, on Nov. 10. The new rule requires contractors and subcontractors to undergo cybersecurity self-assessments or third-party certifications, post results in the Supplier Performance Risk System (SPRS) and provide annual affirmations of continuous compliance.

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