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DoD suspended CMMC Phase 2 amid concerns about cost and burden on small businesses. Now it is hoping those same contractors will embrace cybersecurity practices that are broader, more complex, and potentially more expensive than their existing requirements.

We break down DoD's remarkable explanation for its “Brilliant at the Basics” campaign, the push toward phishing-resistant MFA and broader operational technology security, and NDIA survey data showing what defense contractors already spend implementing and maintaining NIST SP 800-171 and how many lack the resources to manage those requirements.

Will the result of the CMMC Review be a more expensive cybersecurity baseline with less assurance that it is actually being implemented?

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National Defense Magazine: https://www.nationaldefensemagazine.org/articles/2026/8/25/new-cyber-campaign-contradicts-cmmc-pause-expert-says

Brilliant at the Basics: https://dowcio.war.gov/BrilliantBasics/

Phishing resistant MFA: https://youtu.be/7aMxKNNlOxo?si=zX7Iri6uV0uVBJLJ

DIBCAC Top 10: https://summit7.us/blog/tools-to-take-on-nist-800-171

2019 DoD IG Report: https://www.dodig.mil/reports.html/Article/1916036/audit-of-protection-of-dod-controlled-unclassified-information-on-contractor-ow/