On September 10, the Department of Defense (DoD) published its long-awaited final rule for the Cybersecurity Maturity Model Certification (CMMC). This means that beginning November 10, CMMC requirements will start showing up in contracts, and for many manufacturers, the clock is officially ticking.
If you operate anywhere in the defense supply chain, this is not an abstract policy change. It’s a direct requirement that will determine whether your company can win, retain, or even bid on future defense work.
These requirements extend far beyond missile manufacturers, drone builders, or arms producers. Small and mid-sized firms that make parts, tools, materials, and subassemblies are also impacted. Even machine shops, metal fabricators, plastics processors, and service providers could find themselves locked out if they can’t prove compliance.
Why CMMC Matters Now
The defense industrial base (DIB) is massive, encompassing more than 200,000 businesses. These companies, many of them small manufacturers, produce everything from electronic components to precision tooling to advanced aerospace assemblies. For years, adversaries and criminal groups have targeted the DIB to steal intellectual property and disrupt operations.
The DoD’s response is CMMC, a standardized framework that requires contractors and subcontractors to demonstrate they are following baseline cybersecurity practices. Without certification, manufacturers won’t just lose access to prime contracts; they’ll also be cut off from subcontracting opportunities, which ripple down multiple tiers of the supply chain.
CMMC is the new cost of entry. Just as ISO standards or quality certifications once defined who could compete, CMMC is the cybersecurity equivalent. Since it was first announced in 2019, CMMC has gone through several revisions. The current version, CMMC 2.0, is built around three levels of maturity:
- Level 1 (Foundational): Basic safeguarding of Federal Contract Information (FCI).
- Level 2 (Advanced): More robust protection of Controlled Unclassified Information (CUI), aligned closely with NIST SP 800-171.
- Level 3 (Expert): The highest tier, aimed at a smaller number of organizations that handle the most sensitive information, aligned with NIST SP 800-172.
For many manufacturers, especially those working with defense primes, Level 2 will be the requirement. But even Level 1, which seems modest, still mandates documented practices, proof of implementation and verification.
One source of confusion has been timing. Until now, CMMC enforcement was delayed, leading some companies to put it on the back burner. With the final rule published, that delay is over. Starting November 10, CMMC will begin appearing in solicitations.
What It Means for Manufacturers
For manufacturers, the implications of CMMC are significant. Without certification, contracts will be entirely off-limits. Companies that are not compliant at the required level won’t even be able to submit a bid. The requirements also extend beyond prime contractors, as subcontractors and suppliers further down the chain aren’t exempt.
Basically, anyone who handles FCI or CUI will need to comply.
CMMC will also affect business continuity. Noncompliance doesn’t just block new opportunities; it can jeopardize existing contracts, putting long-standing customer relationships at risk. At the same time, compliance may become a differentiator in a competitive supplier market. Manufacturers that move quickly to achieve certification will gain a critical advantage over slower rivals, positioning themselves as more reliable partners for defense primes.
Manufacturers need to treat CMMC compliance as urgent and unavoidable. Here are seven practical steps they should be taking now to avoid being shut out of future contracts:
- Define Your Required CMMC Level. The first step is to determine whether you fall under Level 1, 2, or 3. This depends on the type of data you handle, such as FCI, CUI, or export-controlled data. For manufacturers, this often means customer design files, CAD drawings, specifications, or technical orders shared by primes. Even if you think your shop is only producing “commodity” parts, if you receive DoD drawings or controlled technical data, you are in scope.
- Identify Assets and Data. Map where sensitive information resides and how it flows through your operation. In a manufacturing environment, this often means looking beyond office IT and considering shop floor systems: CNC machines connected to networks, programmable logic controllers (PLCs), industrial PCs, and even cloud-based ERP/MRP systems. Knowing exactly where CUI and FCI live makes it possible to narrow compliance scope and avoid locking down systems that don’t touch defense work.
- Choose a Technical Design. Decide whether an “enclave” environment, secure cloud solution, or enterprise-wide deployment is best. For example, if DoD data only flows into engineering workstations and the ERP, you may be able to isolate those assets in a compliant enclave. But if production data and CAD files are shared across the shop floor, a broader architecture may be required. Manufacturers should consider how often they share files with suppliers, distributors, or customers, since that flow of information will drive design choices.
- Implement the Right Platform. Ensure your IT systems can meet federal security requirements for handling defense-related data. For many manufacturers, this could mean adopting a government-compliant cloud environment, adding encryption to file servers that house CAD/CAM data, or segmenting networks that run production machinery. Aligning your platform early helps avoid costly rework later, especially when older shop floor equipment wasn’t designed with security in mind.
- Seek Qualified Support. Most small and midsized manufacturers don’t have in-house cybersecurity teams. Engaging outside expertise can bridge the gap. Whether through a managed service provider, consultant, or industry association resource, outside partners can help monitor your networked machines, configure secure remote access for maintenance vendors, and ensure your IT environment maps to NIST 800-171A.
- Prepare and Document for Assessment. Documentation is critical. Manufacturers should build a System Security Plan (SSP), update infrastructure maps and data flow diagrams that include production lines, and complete a self-assessment and Plan of Action and Milestones (POA&M). This step often reveals overlooked areas, like USB ports on CNC controllers or shared logins for operators, that need to be addressed before an audit.
- Complete a CMMC Assessment. Finally, work with a certified third-party assessment organization (C3PAO) to validate compliance. This step formally clears the path to eligibility for defense contracts. For manufacturers, being certified can also strengthen trust with primes, who are increasingly looking for suppliers they know will not jeopardize program timelines or sensitive design data.
Manufacturers need to prioritize compliance now to protect their competitiveness, safeguard sensitive data, and ensure they’re positioned to capture the economic upside of defense spending. CMMC is here, enforcement begins November 10, and the time to act is now.
