Consultants and early C3PAO feedback consistently show that roughly 60-75% of self-attested Level 2 packages require significant rework to survive third-party review. The gap is not usually missing controls; it is the quality, granularity, and age of evidence.

Scoping is the single biggest reason Level 2 assessments are failing or stalling in early 2026. Consultants, early C3PAO mock assessments, and readiness reviews consistently show scoping errors in roughly 40-60% of cases. Get the boundary wrong and you either fail outright (under-scoping) or burn six-figure budgets remediating assets that never touch CUI (over-scoping). The DoW Scoping Guide Level 2 (October 2024 final rule version, with 2025 errata) is the canonical reference, yet many organizations still misapply it.

It is January 2026. The October 2025 transition deadline for ISO 27001:2022 has passed. That version is now the only one accepted for new certifications and renewals. There is no brand-new 2026 edition or major controls overhaul. The "latest" changes people keep referring to are still the 2022 revision of Annex A plus the small 2024 Amendment 1 on climate action considerations.

Yet teams with long histories under the 2013 version are running into surveillance audit findings, delayed recertifications, or rework they did not expect. Why does this keep happening to people who should know better?

If you handle (or plan to handle) Controlled Unclassified Information (CUI) on DoW contracts, Phase 2 starts November 10, 2026. That is when the DoW begins requiring Level 2 certification through a Certified Third-Party Assessment Organization (C3PAO) as a condition of award for applicable new contracts.

Submitting a self assessment score of 110, the maximum possible, to the Supplier Performance Risk System may look like a win. In practice, it can expose an organization and its executives to serious legal, financial, and operational risk if the score is not fully defensible.

Under the Department of Justice Civil Cyber-Fraud Initiative, overstating cybersecurity compliance is treated as a knowing or reckless misrepresentation. This is not theoretical. Enforcement actions are already occurring across the defense industrial base.

In today's cutthroat market, certifications like ISO promise to elevate your operations, build trust, and unlock doors. But let's be real: does every business need it? I've advised plenty where it transformed efficiency, yet others where it fell flat. Let's break it down.

NIST SP 800-53 and the Cybersecurity Maturity Model Certification (CMMC) framework often come up together, but they serve different purposes and apply to different audiences. Understanding the distinction helps organizations avoid unnecessary work and compliance confusion.

If you’re involved with CMMC credentials, you’ve probably heard that ISACA is now operating as the CMMC Accreditation Body’s Certification and Credentialing Organization (CAICO). That shift raises a lot of practical questions, especially for current and prospective CCPs and CCAs.

Here’s a clear rundown of what’s changing, what’s staying the same, and what you should pay attention to next.

A CMMC Third Party Assessment Organization (C3PAO) is an independent assessor authorized to evaluate contractor compliance with CMMC requirements. For many CMMC Level 2 contracts, a C3PAO is the gatekeeper to eligibility.

If you support Department of Defense contractors, CMMC applies to you too. Managed Service Providers (MSPs) are often treated as External Service Providers (ESPs) under CMMC, and your role can directly affect a client’s certification and contract eligibility.

CMMC compliance is no longer optional for DoW suppliers. With Phase 1 underway since November 2025, manufacturers need reliable ways to learn the levels, controls, self-assessments, and upcoming third-party requirements without wasting time or money. Here's a prioritized list of the best resources as of January 2026.

If you're a small manufacturer in the DoD supply chain, you've probably seen "FCI" and "CUI" thrown around in contracts or CMMC discussions. These acronyms define what data you handle and which CMMC level you need. Get it wrong, and you risk non-compliance or lost bids.

PIEE stands for Procurement Integrated Enterprise Environment. It's the Department of War's main online system for handling contracts, payments, vendor registration, and more. Think of it as the DoW's big procure-to-pay hub.

Short answer first: There is no single "CMMC portal." The term gets used casually, but compliance actions happen in specific DoW systems depending on what you need to do.

If you're a small manufacturer or supplier trying to submit your CMMC self-assessment right now (Level 1 or Level 2 in Phase 1), you use the Supplier Performance Risk System (SPRS). That's where most people mean when they say "the portal."

If you're a small manufacturer or supplier touching DoW work, DFARS 252.204-7012 is probably already in your contracts (or your prime's subs). It's the core DoD clause titled "Safeguarding Covered Defense Information and Cyber Incident Reporting." In plain terms: protect sensitive unclassified data (Covered Defense Information or CDI, often the same as CUI) on your systems, and report cyber incidents fast, or risk contract breaches, withheld payments, or worse.

If you're a small manufacturer in the DoW supply chain and you've heard "the CMMC auditor is coming," you're probably prepping for a Level 2 assessment. "CMMC auditor" isn't an official job title. It’s what contractors call the independent experts who evaluate your cybersecurity setup when third-party certification is required.

If you're a small manufacturer or supplier in the DoD supply chain, you've likely heard "get CMMC certified" and wondered what it actually means. Short answer: CMMC (Cybersecurity Maturity Model Certification) is the Department of War's program to verify that contractors protect sensitive unclassified information. It focuses on Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) on their systems.

CMMC 2.0 Requirements in 2026: Quick Guide for Small Manufacturers and Suppliers

If you're a small manufacturer or supplier in the defense supply chain, you've probably seen "CMMC 2.0 requirements" popping up everywhere. As of January 2026, Phase 1 is live: the DoW started including CMMC clauses in new contracts back on November 10, 2025. Miss this, and you risk losing subcontracts.

CMMC compliance is not a checklist exercise. It is a structured cybersecurity framework designed to protect Controlled Unclassified Information (CUI) across the defense industrial base. At its core, CMMC Level 2 is built on 14 security domains derived from NIST SP 800-171.

CMMC Level 2 assessments fail for predictable reasons. Most issues are not advanced technical gaps. They are basic execution mistakes that surface during scoping, documentation, and evidence review.