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DoD already solved the problem of CMMC requiring NIST SP 800-171 Rev. 2 while other cybersecurity requirements moved to Rev. 3. Then it suspended CMMC Phase 2.

Now the FAR CUI rule is approaching with Rev. 3, CMMC remains tied to Rev. 2, and defense contractors could once again find themselves juggling different cybersecurity baselines for the same data. We break down how DoD got here, the options for fixing it, and why CMMC reform could make the problem even more complicated.

Crisis Averted (2024): https://youtu.be/voziZRAMvv4?si=LLlm4VUmBR-G3hno

Phase 2 Suspension: https://www.war.gov/News/Releases/Release/Article/4542329/forging-the-arsenal-of-freedom-department-of-war-suspends-cmmc-phase-ii-require/

Unified Agenda: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0790-AM01

DoD CIO (Feb 2026): https://www.linkedin.com/posts/dow-cio_ot-cyber-cybersecurity-activity-7433151492745879552-b_It

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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?

Register for Summit 7 Live: https://www.summit7.us/s7live

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/

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Everyone says CMMC has an assessor shortage.

The July numbers tell a different story.

We break down the latest CMMC ecosystem data, DoD's own demand estimates, and why the real bottleneck is contractor readiness, not assessment capacity.

Register for Summit 7 Live: https://www.summit7.us/s7live

Cyber AB Town Hall: https://cyberab.org/News-Events/Town-Hall

DoD Capacity Estimates: https://www.federalregister.gov/d/2024-22905/p-1240