CMMC 2.0 "Final" Rule: Minus the bullsh*t (AKA coloring with crayons)

Alright, let’s cut through the noise and get to what really matters about the Cybersecurity Maturity Model Certification (CMMC) 2.0. And you might notice the "" around the word Final in my title, that's because I would bet my first born kid that there will be changes as this rule is going to change in some way in the near future (watch).

This 400+ page monster boils down to: the Department of Defense (DoD) wants to know if companies working with them can keep their sensitive information safe. No jargon. Just reality: If your company can’t prove it, you’re out of the game—no contracts, no extensions, no money.

Here’s what you absolutely need to know without having to read the whole thing (you’re welcome).

What’s the Big Idea Here?

The DoD is rolling out a 3-level framework to, in theory, make sure everyone from Fortune 500s to small businesses can actually protect sensitive data (why start now I ask). Think of it as three hurdles to prove you’re good enough to play in the big leagues. No bluffing—either you meet the standards, or you don’t.

• Level 1 (Foundational): Easy stuff. Companies just self-assess—check their own work like an open-book test. This is for those handling basic information like unclassified contract details. You screw up here? It’s embarrassing, like choke yourself embarrassing but lots of companies are still at this level.
• Level 2 (Advanced): Now it gets interesting. Outside assessors (hello additional costs) will come snoop around every three years to make sure your security systems are tight. This level applies to contractors handling Controlled Unclassified Information (CUI)—which is basically the government’s version of “don’t let this leak.” Which has never been an issue, lol.
• Level 3 (Expert): This is DEFCON 1 territory—government audits only (yes more costly). If your company handles the most sensitive information, the Defense Industrial Base Cybersecurity Center will send in the big dogs to make sure you’re playing by the rules.

What Happens If You Flunk? ??

Simple. No CMMC compliance = No contracts. You can’t fake this either. The rule has teeth (well money=teeth so yeah there are those). If a company lies about meeting requirements, the Department of Justice may come knocking with False Claims Act violations (JDSupra, 2024).

And if you don’t get certified on time? You might as well kiss those sweet DoD contracts goodbye (or at least expect them to be potentially affected). Miss your chance, and your competitors will happily take your place (Charles IT, 2024).

The Timeline: Hurry Up, or Miss Out ??♂?

The first phase starts December 15, 2024, when contractors will need to self-assess to be eligible for new contracts. Over the next three years, things ramp up:

• 2025: Third-party assessments required for sensitive work.
• 2026: Higher-level audits start.
• 2028: Full rollout—no certification, no game.

The message is clear: Start now or risk being out of the loop when contracts go live (Holland & Knight, 2024).

Here’s What It Means for You

You don’t need to be a cybersecurity genius. Just make sure your compliance people get moving. They’ll need to:

1. Run self-assessments now (don’t wait for DoD to show up, but for the record I fundamentally hate that self-assessments are even a thing).
2. Plan for third-party audits where necessary (get your budget lined up).
3. Stay vigilant—your people will need to file annual affirmations saying, “Yep, we’re still compliant!” (and no lying about it, or the DOJ will make it hurt, or at least they are sure saying they will).

Bottom Line

If your company’s business depends on the DoD, compliance with CMMC 2.0 isn’t optional—it’s survival. You’ve got until December 2024 to get your act together. Ignore this at your peril. It’s not just about keeping up with the Joneses—it’s about staying in business. Time to get those certifications done. Fast.

Bibliography

• Department of Defense. (2024). Cybersecurity Maturity Model Certification Program Final Rule Published. Retrieved from Defense.gov
• Holland & Knight. (2024). 15 Key Takeaways from the Final CMMC Program Rule Issued by DOD. Retrieved from Holland & Knight
• Cozen O’Connor. (2024). Department of Defense Publishes Final Rule on Cybersecurity Maturity Model Certification. Retrieved from JDSupra
• Charles IT. (2024). 2024 CMMC Final Rule Published: What You Need to Know. Retrieved from Charles IT Blog
• Sheppard Mullin. (2024). Countdown to Compliance: DoD Finalizes the CMMC Program Rule. Retrieved from Government Contracts & Investigations Blog