Why the Three-Year DFARS 7012 Inspection Cycle Is Insufficient for CMMC Compliance

The long-anticipated release of the Cybersecurity Maturity Model Certification (CMMC), now codified under 32 CFR Part 170, has shifted the compliance landscape for government prime contractors and subcontractors alike. While the existing DFARS 7012 clause requires contractors to implement NIST SP 800-171 controls and submit self-assessment results, its three-year inspection cycle is proving to be an outdated framework for the more rigorous and real-time requirements of CMMC.?

With DFARS 252.204-7021 now mandating CMMC certification as a prerequisite for contract awards, contractors must take immediate, proactive steps to ensure compliance. Here's why the traditional three-year inspection cycle is inadequate and what companies need to do to prepare.?

The Gaps in the Three-Year DFARS Inspection Cycle?

1. Reactive Rather Than Proactive DFARS 7012 emphasizes periodic self-assessments and government audits, often leaving room for complacency. Companies may prioritize compliance only when inspections are imminent, resulting in security gaps. CMMC, however, demands continuous monitoring, documentation, and improvement to align with its maturity-based framework.?
2. Increased Threat Landscape Cyber threats evolve daily, not every three years. A static approach to compliance means vulnerabilities can persist, leaving critical Defense Industrial Base (DIB) assets exposed. With adversaries targeting Controlled Unclassified Information (CUI), a three-year cycle simply can't keep pace.?
3. Certification vs. Assessment Under DFARS 7012, self-assessments allow contractors to self-certify compliance, often leading to subjective interpretations of requirements. CMMC eliminates this flexibility, requiring third-party audits to validate adherence to NIST 800-171 and additional security practices, ensuring a more robust and credible compliance posture.?

Why Immediate Action is Crucial?

CMMC is no longer a distant requirement—it’s here. All DIB contractors face the dual challenges of preparing for third-party assessments and addressing the heightened security expectations of 32 CFR Part 170. Non-compliance risks are significant: lost contracts, reputational damage, and even potential legal consequences.?

• Integration of Continuous Monitoring: All contractors must shift to a mindset of ongoing compliance, implementing continuous monitoring solutions to track and mitigate risks in real time.?

• Documentation and Evidence: CMMC assessments require thorough documentation to demonstrate compliance. Companies should review and enhance their System Security Plans (SSPs), Plans of Action and Milestones (POA&Ms), and incident response strategies.?

• Supply Chain Resilience: Prime contractors will increasingly scrutinize their supply chains. Contractors need to show they are not only compliant but capable of sustaining compliance over time.?

Preparing for CMMC: Steps Contractors Should Take Now?

1. Gap Analysis Conduct a comprehensive review of your current DFARS 7012 compliance against the CMMC requirements. Identify deficiencies and prioritize remediation efforts.?
2. Update Policies and Procedures Policies written to meet DFARS 7012 requirements may lack the depth needed for CMMC. Focus on areas like incident response, access control, and multifactor authentication.?
3. Invest in Training Employee awareness is key. Regular training ensures that everyone understands their role in maintaining compliance and mitigating risks.?
4. Engage with Third-Party Experts Partner with CMMC Registered Provider Organizations (RPOs) to guide your organization through the certification process and provide readiness assessments.?
5. Leverage Technology Use tools designed for compliance management, such as Security Information and Event Management (SIEM) solutions, vulnerability scanners, and endpoint protection systems.?

Conclusion?

The transition from DFARS 7012's three-year inspection cycle to the real-time, rigorous requirements of CMMC represents a seismic shift for the Defense Industrial Base. Companies can no longer afford to take a passive approach to compliance. The publication of 32 CFR Part 170 and enforcement of DFARS 252.204-7021 underline the urgency for immediate and sustained action.?

By adopting a proactive, continuous compliance strategy today, companies can safeguard their businesses, maintain contractual eligibility, and contribute to the overall cybersecurity resilience of the nation.?

Written By: Blaze Baker, Information Technology & Assurance Executive