How To Accelerate CMMC Compliance: Key Actions Despite Rulemaking Delays

Accelerate CMMC Compliance Introduction

The ongoing development of the Cybersecurity Maturity Model Certification (CMMC) has created both excitement and apprehension for companies working with the Department of Defense (DOD). Initially proposed to strengthen the protection of Controlled Unclassified Information (CUI) throughout the defense supply chain, CMMC promises to introduce new obligations for contractors and subcontractors alike. Although the final release of CMMC occurred only in the third quarter of 2024, one point is clear: waiting for the rule to take shape will likely leave many companies scrambling to adapt at the last minute.

In parallel, the foundation of CMMC (NIST Special Publication (SP) 800-171) is also undergoing significant refinement. These two processes, although related, operate on different timelines, thereby creating a sense of uncertainty across the defense industrial base. Yet, this uncertainty should not slow your progress toward compliance. Instead, it underscores the importance of laying a strong cybersecurity foundation now, so you can pivot quickly if new requirements emerge.

Understanding the Current Landscape: CMMC and NIST 800-171

When all levels are fully in force, CMMC will serve as a verification mechanism to ensure that contractors have robust cybersecurity controls necessary to protect sensitive information. Although the DOD has been tight-lipped about precise timelines, many experts predict that procedural reviews and assessments by other agencies, such as the Small Business Administration, will further delay the official release date of CMMC. This extended timeframe has the potential to confuse companies unsure of which controls to implement and when.

Meanwhile, NIST 800-171, the publication that outlines security standards for non-federal companies handling CUI, remains the anchor to which CMMC is tethered. Revisions to NIST 800-171 are likely to be finalized by the end of 2023, and these updates will mainly address refinements, clarifications, and occasional new additions drawn from NIST 800-53. While these changes are best described as “tailoring” rather than an overhaul, they are still vital. They will help businesses align security practices with a modern threat landscape, ensuring that CUI is well protected from evolving cyber dangers.

Latest Developments in NIST 800-171 Revisions

Although the revisions to NIST 800-171 focus on enhancing clarity, they may introduce new controls or reorganize existing ones. While this trajectory of change shouldn’t upend your overall approach, it does highlight that compliance is not a one-and-done effort. Every time NIST updates its guidelines, companies must confirm that they remain aligned with the new standards. The gap between NIST 800-171’s expected finalization and CMMC’s ultimate rulemaking will be challenging to navigate. There is a possibility that the DOD could implement a “class deviation” to delay mandatory compliance with the new version. Yet relying on any delay is risky. Should that deviation not materialize, companies that halted their compliance efforts will be hard-pressed to update controls quickly enough to meet immediate demands.

“Even modest postponements in rulemaking can lead to significant business disruptions,” says John Pohlman, a recognized cybersecurity leader at Tanner. “For most companies, stopping or slowing cybersecurity enhancement efforts only increases their long-term risks and costs.”

Given these realities, the time to refine your cybersecurity processes is now. The greater your preparedness, the smoother the transition will be once CMMC is formally implemented.

Key Actions to Maintain Momentum

Rather than waiting for the dust to settle on both NIST 800-171 revisions and the CMMC rulemaking, businesses should remain proactive. Taking deliberate steps to fortify your security posture not only mitigates risk but also positions you favorably for future government contracts.

One of the most critical steps is a comprehensive assessment of your current cybersecurity measures. By conducting a gap analysis against the existing NIST 800-171 requirements, you can identify both your strong points and vulnerabilities. Common gaps often include inconsistent access controls, insufficient incident response procedures, or a lack of comprehensive security training for staff. Once those areas are identified, establishing a clear roadmap for remediation prioritizes the most significant risks first, balancing the practical realities of limited time and resources.

Another essential practice during these months of uncertainty is to stay informed about NIST’s ongoing revision process. Tracking official NIST communications and reviewing published drafts can help you better anticipate the direction and substance of these modifications. Early knowledge empowers businesses to train employees, restructure policies, or enhance system configurations well before the updated guidelines are locked in. This vigilance ensures you will be prepared to pivot smoothly if specific key controls or processes are re-engineered.

Engaging in voluntary assessments, such as the Joint Surveillance Voluntary Assessment Program, provides another avenue to enhance your readiness. Although formal CMMC certification is not yet possible, these structured reviews measure your compliance with the current iteration of NIST 800-171. In addition to receiving guidance on corrective actions, participating companies can have their scores transferred to a CMMC Level 2 certification once the final rules take effect. This program serves as a preview of how well your cybersecurity posture aligns with the industry and government expectations.

Finally, do not underestimate the importance of organizational culture and leadership support. Compliance cannot be relegated solely to IT or cybersecurity specialists; it requires participation from finance, human resources, legal, and operations to succeed long term. Regular training sessions, cross-department collaboration, and clearly defined responsibilities will embed a security-first mentality throughout your company. Tanner’s advisory teams emphasize this holistic approach in client engagements, ensuring that improvements in technology align with process optimization and personnel development.

Accelerate CMMC Compliance Conclusion

While delays in finalizing the CMMC rule may provide short-term breathing room, they are not a valid rationale for complacency. Companies that take proactive measures now, such as conducting thorough gap analyses, monitoring NIST’s revision process, participating in voluntary assessments, and fostering a culture focused on cybersecurity, will be best positioned to adapt once the rules become official. Beyond compliance, robust security practices protect your organization’s most valuable data, instill confidence in your stakeholders, and open doors to future contracting opportunities.

Tanner is committed to helping businesses stay ahead of these evolving requirements through expert guidance, tailored assessments, and ongoing support. By acting promptly, you can secure a competitive advantage, mitigate risk, and ensure the continuity of your operations in a rapidly shifting cybersecurity landscape.