Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874

The regulation that finalizes CMMC guidance for DoD contracting officers and program managers officially goes into effect on November 10th, 2025. The highlight of the regulation is the final text of DFARS clause 252.204-7021 which tells contractors which CMMC level they need to achieve in order to take award of a contract. But the regulation also created DFARS provision 252.204-7025 which officially notifies offerors of the requirements contained in the 7021 clause and it's only three paragraphs long!

Summit 7 Live: https://www.summit7.us/S7Live

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of

Register for the upcoming webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here

It's official: CMMC Phase 1 begins on November 10th, 2025 when the 48 CFR CMMC final rule goes into effect. After that point all new Department of Defense/War contracts will contain some level of CMMC requirement. But just when things seem certain, people are wondering about the recent class deviation regarding DFARS clause 252.204-7021. Is the use of the CMMC clause actually suspended? Spoiler: no, not even close.

Final Rule Webinar: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here?hsCtaAttrib=195767465874

Summit 7 Live: https://www.summit7.us/S7Live

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

2025 CMMC Final Rule (48 CFR): https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of

Aug Class Deviation: https://www.acq.osd.mil/dpap/policy/policyvault/USA001756-25-DPCAP.pdf

A lot of defense contractors are betting that the DoD will only require CMMC Level 2 self-assessments during the first 12 months of CMMC (“Phase 1”). Since December 2024 there have been three official policies outlining what can be required in Phase 1 and none of them prohibit Level 2 certification assessments. Instead, every policy we can find reinforces the idea that many companies will be required to achieve CMMC Level 2 certification in Phase 1. In this episode we walk through all 3 policies so you can decide for yourself if that's a risk you want to take with your business.

Summit 7 Live: https://www.summit7.us/S7Live

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

32 CFR 170.3(e): https://www.ecfr.gov/current/title-32/part-170#p-170.3(e)

The January Memo (PDF): https://dodprocurementtoolbox.com/uploads/DOPSR_Cleared_OSD_Memo_CMMC_Implementation_Policy_d26075de0f.pdf

The July Memo (PDF): https://dodprocurementtoolbox.com/uploads/PTDO_Do_D_CIO_Memo_Resources_for_CMMC_Implemtation_dtd_20250728_25_T_2704_cleared_20250807_e53aa02e78.pdf

The Summer is all but over, but that's ok because the CMMC program is just getting started! On this week's episode, we cover the Cyber AB's Monthly Townhall for August and break down all the things you need to know.

Things like:

• Did assessment progress slow down?

• Are there any reported failures?

• Are people finally interpreting the 10-day post assessment rule correctly?

• Will the DoD be represented at CS5?

• What is the C3PAO Advisory Council?

And so much more... Tune in to find out!

Summit 7 Live: https://www.summit7.us/S7Live

Women of CMMC Dinner: https://cs5global.org/women-of-cmmc-dinner/

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025

Golden Dome promises to be the largest and most complex defense initiatives in American history. Countless contractors, subcontractors, and suppliers will be called on to help build the ultimate system of systems. But those suppliers are the targets of cyber espionage, disruption, and IP theft – regardless of their size. So it's no surprise that as the Golden Dome program lifts off, the DoD is out in front with some pretty intense cybersecurity requirements.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

DFARS 7012: https://youtu.be/cy4e28YAkXU?si=KvezY7Vu7zXf9qYZ

Register for Secure The DIB: https://securethedib.us/

Voluntarily disclose your DFARS cybersecurity noncompliance? That'll be $1.75M, please. This week we're looking at the details of a recent False Claims Act settlement involving a small defense contractor. Turns out that mistaking export controls for cyber controls and relying on the wrong external service providers can controls can cost you a lot of money.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

DOJ Settlement: https://www.justice.gov/opa/pr/california-defense-contractor-and-private-equity-firm-agree-pay-175m-resolve-false-claims

DFARS 7012: https://youtu.be/cy4e28YAkXU?si=KvezY7Vu7zXf9qYZ

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025

We can't remember a 30-day stretch in the history of CMMC that had more milestones and memos than July 2025. The ecosystem is closing-in on 300 Level 2 certified companies, mega primes have put everyone on notice, the phased roll-out is weeks away, the secretary of defense, the Army Corps of Engineers, you name it – everybody is gearing up for the big day. This week we're talking about 5 things you might have missed while on summer vacation.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

Secure the DIB: https://www.summit7.us/secure-the-dib-2025

Lockheed Memo: https://youtu.be/gMHWhXhe_Uo?si=FtkziMSqBWfzWAWp

SECDEF Memo: https://media.defense.gov/2025/Jul/22/2003759081/-1/-1/1/ENHANCING-SECURITY-PROTOCOLS-FOR-THE-DEPARTMENT-OF-DEFENSE.PDF

48 CFR Progress: https://youtu.be/Q2qeJhA4oIs?si=b1bRqxcR0MbTOWIj

USACE Notice: https://sam.gov/workspace/contract/opp/0b14a472d53b454ea6bca0893b2647d0/view

Register for Secure The DIB: https://www.summit7.us/secure-the-dib-2025

The Cyber AB brought the CMMC Ecosystem together once again for the July 2025 installment of their monthly Town Hall series. Join us for this week's show as we discuss all the information distributed during the meeting that you need to know; answers to questions like:

After your assessment, you get 10 days to do what?

How many CMMC assessments took place in July?

Does anyone fail their assessment, and do they keep track of them? And so much more... Tune in to find out!

Secure the DIB: https://www.summit7.us/secure-the-dib-2025

CMMC Just Crossed A *Huge* Rulemaking Milestone: https://youtu.be/Q2qeJhA4oIs?si=IQ1bYI6jH3VGuxAa

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall