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Stop Kidding Yourselves, Contractors – CMMC Requirements Aren’t ‘Still in Flux’

“We don’t want to start with CMMC compliance until the requirements are finalized,” is something we hear a lot from contractors. Seriously, if we made a dollar every time, we’d probably have enough to fully fund your compliance journey by now.

Aside from being misguided, this mindset is dangerous for your business. As providers of IT support for government contractors in Fredericksburg and throughout Virginia, we’ve seen firsthand how this “wait and see” approach can backfire spectacularly.

“Flux” Is a Misconception. Here Are the Facts.

Let’s clear this up once and for all: CMMC Level 2 requirements are not in flux. They haven’t been for quite some time.

The foundation of CMMC Level 2, NIST SP 800-171, has existed since 2017. That’s right, the core security controls your organization needs to implement have been stable for over seven years.

Plans for the CMMC 2.0 framework were first announced in November 2021. The final rule in the regulation – which “outlines the mechanisms that DOD will use to prescribe cybersecurity standards for safeguarding federal contract information (FCI) and controlled unclassified information (CUI).” – was published in the Federal Register on October 15, 2024. It went into effect on December 16, 2024.

That means we’re six months past the point of no return. The phased rollout isn’t some far-off event. It’s happening right now. Any remaining “changes” are merely clarifications, not fundamental rewrites of what’s expected.

Why Waiting to Seek CMMC Support for Government Contractors Is So Risky

The cost of delaying your CMMC compliance efforts grows with each passing month. The longer you delay, the more you’ll risk:

Missing Out on Contracts

Achieving CMMC certification is a marathon, not a sprint (Level 2 compliance can take anywhere from 9 to 18 months to attain). Although it’s never too late to start, by the time CMMC requirements appear in your contracts, you’ll be way behind competitors if you don’t get moving.

Revenue Loss

As primes prioritize compliant subcontractors, non-compliant companies will find themselves losing business to competitors who took CMMC seriously earlier.

DFARS 7012 Non-Compliance

Remember, DFARS 252.204-7012 is already active and requires implementation of NIST 800-171. Your organization is already obligated to comply with that, regardless of CMMC’s rollout schedule.

“Still in Flux” Is a Red Flag in Your Risk Profile

Prime contractors aren’t waiting for the government’s timetable; they’re already vetting their supply chains. When you tell one that you’re waiting because “CMMC is still up in the air,” you’re sending a clear message: cybersecurity isn’t a priority for your organization.

Primes need trusted partners in their supply chain, not security liabilities. In almost 30 years providing IT support for government contractors in Fredericksburg and beyond, we’ve seen plenty of primes drop subcontractors who weren’t taking compliance seriously enough.

What “Still in Flux” Really Means (Hint: It’s Procrastination)

When a contractor tries to argue that CMMC is “still in flux,” what they’re really saying is one of three things:

1. “I Haven’t Scoped My Environment”

Understanding what systems handle CUI and how to secure them requires effort. It’s easier to delay this work by claiming the requirements themselves aren’t settled.

2. “I’m Overwhelmed”

The 110 controls in NIST 800-171 can seem daunting. Rather than tackle them systematically, some contractors find it easier to wait for a magical “final version” that will somehow be less complex (in case we haven’t made it clear by now: that’s not going to happen).

3. “I’m Hoping This Will Go Away”

Some contractors are banking on political changes or further delays. This is a risky gamble; even though the full CMMC program rollout is phased, you’re going to start feeling the pressure to get certified long before you see CMMC requirements appear in contracts.

All these concerns come down to the same fundamental problem: a lack of clarity about what’s actually needed for CMMC 2.0 compliance. The good news is, getting an accurate scope for your business can actually be a relatively fast and painless process. You just have to enlist an experienced IT support team to help.

The Reality of the CMMC Compliance Timeline?

We can’t tell you exactly how long achieving compliance will take for your organization without a 1:1 meeting (which you can book here). That’s because your timeline will depend on your starting point and organizational complexity.

The process does tend to be lengthy, though, as it includes:

  • Documenting policies and procedures
  • Implementing technical controls
  • Training staff
  • Collecting evidence
  • Remediating gaps

Even for smaller organizations, this takes significant time and resources. It’s not like contractors are oblivious to this fact. The people we speak to are often so overwhelmed at the thought of it that taking the first step feels impossible. But the sooner you begin, the more manageable the process becomes.

The Fix: Get Real, Get Scoped, Get CMMC Support for Government Contractors

Instead of using “still in flux” as a crutch, take these practical steps:

1. Get a Proper Scoping Assessment

First, work with an RPO who understands CMMC (that’s us!) to determine exactly which systems handle CUI and need to be protected.

2. Start with a Gap Assessment

Compare your current security posture against CMMC requirements to identify what needs fixing. This provides a realistic roadmap rather than an overwhelming list of controls.

3. Reduce Scope Intelligently

Don’t try to make your entire organization CMMC-compliant if it’s not necessary. Through strategic system design and careful data flow management, you can significantly reduce your compliance burden.

4. Get Specialized IT Support for Government Contractors in Fredericksburg

Reducing risk, accelerating progress, and often lowering overall costs – there are some pretty compelling reasons to partner with a guide like Infinity Technologies. More than anything, our team understands both the technical and documentation requirements for successful certification – so you don’t have to.

Don’t Wait Any Longer

The CMMC compliance timeline isn’t some distant future concern. For contractors who haven’t begun preparing, every day of delay increases business risk and compliance costs. The time to start isn’t when requirements appear in your contracts. It’s now.

Still hesitant? Let us ease your concerns and help you get going. Book a 1:1 with our client consultants Jeff or Curtis today to set out some manageable first steps.