Breaking News: 32 CFR Final Rule for CMMC Clears Regulatory Review 

The landscape for defense contractors is changing with the recent update to the Cybersecurity Maturity Model Certification (CMMC) regulations. The 32 CFR Final Rule marks a significant transition, moving CMMC from a conceptual framework to a codified law. This is a pivotal moment for the defense industry, emphasizing the government’s commitment to cybersecurity. Let’s unpack what this rule means for you and how you can prepare for the impending changes. 

CMMC Becomes Law: Understanding the 32 CFR Final Rule

The 32 CFR Final Rule does more than just update regulations—it embeds CMMC firmly within the legal requirements for defense contractors. After passing through the Office of Information and Regulatory Affairs (OIRA) and facing a 60-day Congressional review, it is set to become law by Q4 2024. This rule establishes the structure and expectations for cybersecurity across the defense contracting landscape. 

Clarifying the Misconceptions: What 32 CFR Does and Does Not Do

While the 32 CFR Final Rule establishes CMMC as a legal standard, it does not yet mandate compliance for contract awards. That step will be covered by the upcoming 48 CFR rule, which will specify how CMMC requirements are integrated into contracts.  

Understanding the roles of these two rules:

  • 32 CFR: Establishes the CMMC framework and sets out the assessment and compliance requirements. 
  • 48 CFR: Will make compliance a requirement in actual defense contracts, marking the real test of your cybersecurity measures. 

CMMC Rollout: What You Can Expect

With the CMMC becoming official law, its full implementation in defense contracts will occur through a phased approach over three years starting in 2025. Here’s what this means for your business: 

  • Preparation is Key: The phased implementation grants you time to adapt to the new requirements, but it’s essential not to be complacent. Starting your preparation early will not only give you a competitive edge but also ensure that you are fully compliant when your specific contracts come under scrutiny. Engage with C3PAOs, begin assessing your cybersecurity framework, and address any gaps sooner rather than later. 
  • Uncertainty in Timing: It’s unclear which contracts will be first to require CMMC compliance, adding a layer of unpredictability. This uncertainty makes readiness not just beneficial but crucial. Being among the first to achieve compliance could position you favorably for early opportunities and set a benchmark for others in your industry. 
  • Strategic Advantage: Beyond immediate compliance, the phased rollout of CMMC offers a strategic advantage to those who move quickly. Early adopters can leverage their compliance status to secure new contracts and build a reputation as leaders in cybersecurity within the defense sector. This can lead to increased trust and potentially more business as you demonstrate your commitment to safeguarding sensitive government data. 

Compliance Requirements Under 32 CFR

The new rule sets the stage for rigorous compliance checks: 

  • Prove Compliance: You will need to demonstrate that you meet the CMMC level required for each contract as stipulated. 
  • Verification Process: Contracting officers will utilize the Supplier Performance Risk System (SPRS) to confirm your compliance. 
  • Continuous Compliance: It’s not enough to be compliant at the start; you must maintain this throughout the contract duration. 

Assessments and Preparations

The start of official CMMC assessments is near, making now the time to get ready: 

  • Engage with C3PAOs: Identify certified third-party assessors who are able to perform the CMMC assessment as the CMMC program becomes implemented. 
  • Understand the Role of DIBCAC: For high-level assessments, familiarize yourself with how the Defense Industrial Base Cybersecurity Assessment Center operates. 

How to Prepare Now

With the final rule about to be published and the countdown to compliance beginning, here’s what you can do right now to ensure your business is ready: 

  • Assess Your Current Compliance: Conduct a thorough review of your cybersecurity posture to identify any gaps that could prevent you from meeting CMMC 2.0 requirements. Help Desk Cavalry, as your trusted Managed Service Provider (MSP), can help by performing a detailed assessment of your systems and security measures to identify areas that need attention. 
  • Determine Your Certification Level: Understanding which CMMC level your contracts require is crucial for your compliance efforts. Help Desk Cavalry can guide you through this process, ensuring you know exactly which certification level to target based on the sensitivity of the information your business handles. 
  • Partner with Help Desk Cavalry: As an MSP with deep expertise in cybersecurity, Help Desk Cavalry is equipped to support you in implementing the necessary security measures and managing your IT systems to meet CMMC 2.0 standards. We’ll help ensure your systems are secure, compliant, and ready for certification. 
  • Stay Informed: Keep a close eye on the Federal Register for the publication of the final rule. 

Staying proactive is crucial as you navigate the complexities of CMMC 2.0. Begin by assessing your current cybersecurity posture, identifying the CMMC certification level needed for your business, and actively engaging with experts who can ensure you meet these new requirements. Help Desk Cavalry specializes in helping companies like yours not only prepare for but thrive under these new regulations. Let us help you secure your future in the defense industry. 

For more information on the 32 CFR Final Rule and its upcoming implementation, visit the government site here: https://www.reginfo.gov/public/do/eoDetails?rrid=589561