The debate over Cybersecurity Maturity Model Certification (CMMC) implementation is definitively over. With the Office of Information and Regulatory Affairs (OIRA) clearing the Defense Department's acquisition rule in August 2025, CMMC has transitioned from policy aspiration to contractual requirement. By October 2026, contractors across the defense industrial base will face a stark reality: achieve CMMC compliance or forfeit eligibility for Department of Defense (DoD) contracts.
The numbers paint a concerning picture. Across a defense supply chain encompassing 220,000 to 300,000 contractors and subcontractors—with approximately 80,000 requiring Level 2 certification—only 270 organizations held final CMMC certificates as of late August 2025. This dramatic gap between requirement and readiness presents significant supply chain disruption risks that could impact national security and defense readiness.
The CMMC compliance gap represents more than a bureaucratic hurdle; it constitutes a potential national security vulnerability. The defense industrial base includes thousands of small and medium-sized businesses (SMBs) that handle Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) daily. These organizations often lack dedicated cybersecurity resources, making CMMC compliance particularly challenging.
The timeline exacerbates the challenge. With implementation beginning in late 2025 and full enforcement by 2026, contractors have a narrow window to achieve compliance. Traditional approaches—hiring full-time Chief Information Security Officers (CISOs), building internal security teams, and developing compliance programs from scratch—are neither feasible nor cost-effective for most SMBs.
State-sponsored adversaries, particularly those tracked as Volt Typhoon and Salt Typhoon, have demonstrated sophisticated capabilities to infiltrate critical infrastructure and maintain persistent access. These campaigns specifically target telecommunications, energy, transport, logistics, and public services—sectors integral to defense operations. The defense industrial base sits squarely within this threat landscape, making CMMC compliance not just a contractual requirement but a national defense imperative.
Recognizing the potential for supply chain disruptions, the DoD has implemented several strategic initiatives to support contractor compliance while maintaining supply chain continuity:
Phased Implementation Approach: The DoD is implementing CMMC requirements in phases, beginning with Level 1 self-assessments for FCI handling and progressing to Level 2 third-party assessments for CUI environments. This graduated approach allows contractors time to build capabilities while maintaining immediate protection for sensitive information.
Centralized Coordination: Under acting DoD CIO Katie Arrington's leadership, a steering group coordinates cybersecurity efforts across the Defense Industrial Base (DIB). This centralized approach ensures consistent implementation and provides contractors with clear guidance and support resources.
Intelligence Sharing Enhancement: The DoD is promoting participation in Information Sharing and Analysis Centers (ISACs) to facilitate real-time threat intelligence sharing among contractors, suppliers, and government agencies. This collaborative approach enhances collective defense capabilities while reducing individual compliance burdens.
Supplier Prioritization: The DoD is prioritizing critical suppliers based on their strategic importance to defense operations, providing targeted support and resources to ensure these organizations achieve compliance first.
Virtual Chief Information Security Officer (vCISO) services and Managed Security Service Providers (MSSPs) have emerged as the most viable solution for addressing the CMMC compliance gap at scale. These service models offer several critical advantages:
Expertise Accessibility: vCISO services provide SMBs access to senior-level cybersecurity expertise without the cost and complexity of full-time hiring. This model enables contractors to leverage seasoned professionals who understand both CMMC requirements and practical implementation challenges.
Scalable Implementation: MSSPs can standardize CMMC compliance processes across multiple client organizations, creating economies of scale that reduce per-client costs while maintaining quality and consistency.
Technology Integration: Modern vCISO platforms integrate artificial intelligence and automation to streamline compliance activities, from initial gap assessments to ongoing monitoring and reporting.
Continuous Compliance: Unlike point-in-time consulting engagements, vCISO and MSSP models provide ongoing support to maintain compliance as requirements evolve and threats emerge.
GetCybr exemplifies the technological innovation driving vCISO service evolution. Their AI-powered platform addresses key CMMC compliance challenges through:
Automated Risk Assessments: GetCybr's platform conducts comprehensive NIST SP 800-171 gap assessments, automatically identifying control deficiencies and prioritizing remediation efforts based on risk and implementation complexity.
Intelligent Compliance Reporting: The platform generates System Security Plans (SSPs) and Plans of Action and Milestones (POAMs) that align with CMMC requirements, reducing documentation burden while ensuring accuracy and completeness.
Continuous Monitoring: AI-driven monitoring capabilities track control implementation status, identify compliance drift, and alert stakeholders to potential issues before they impact certification status.
MSSP Enablement: GetCybr's platform enables MSSPs to scale their CMMC services efficiently, providing standardized methodologies, automated workflows, and client management capabilities that support rapid expansion.
Evidence Management: The platform automates evidence collection and management, ensuring organizations maintain the documentation necessary for both self-assessments and third-party evaluations.
The CMMC compliance gap represents a significant market opportunity for qualified vCISO and MSSP providers. Conservative estimates suggest that 80,000 organizations will require Level 2 compliance, with many more needing Level 1 implementation. This demand creates opportunities for:
Established MSSPs: Existing managed security providers can expand their offerings to include CMMC-specific services, leveraging their client relationships and operational capabilities.
Specialized vCISO Providers: Organizations focused exclusively on virtual CISO services can capture market share by developing CMMC expertise and scalable delivery models.
Technology Vendors: Platforms like GetCybr can enable partner ecosystems, providing technology infrastructure that allows smaller consultancies and regional MSSPs to compete effectively.
Regional Providers: Local and regional cybersecurity firms can serve SMBs in their geographic areas, offering personalized service combined with technology-enabled efficiency.
Organizations seeking to capitalize on CMMC-driven demand should consider the following strategic elements:
Partnership Development: Establishing relationships with Certified Third-Party Assessment Organizations (C3PAOs) ensures clients can progress from self-assessment to third-party certification seamlessly.
Technology Integration: Leveraging platforms like GetCybr's enables rapid scaling while maintaining service quality and consistency across multiple clients.
Specialization Focus: Developing deep expertise in specific CMMC levels or industry verticals allows providers to differentiate their offerings and command premium pricing.
Documentation Standardization: Creating templates, playbooks, and standardized processes reduces delivery time and ensures consistent outcomes across client engagements.
Staff Development: Investing in Registered Practitioner Organization (RPO) credentials and CMMC-specific training ensures staff can deliver authoritative guidance to clients.
The successful implementation of CMMC compliance across the defense industrial base requires rapid scaling of vCISO and MSSP services. This scaling creates positive economic effects:
Job Creation: Demand for cybersecurity professionals will increase significantly, creating opportunities across skill levels from technicians to senior practitioners.
Innovation Acceleration: Competition among service providers will drive technological innovation, improving efficiency and reducing compliance costs over time.
Supply Chain Strengthening: Enhanced cybersecurity across the defense industrial base reduces vulnerabilities that adversaries might exploit, strengthening national security posture.
Small Business Support: vCISO and MSSP models enable SMBs to compete for defense contracts they might otherwise be unable to pursue due to cybersecurity requirements.
The CMMC implementation timeline is aggressive but achievable with proper market preparation. Key recommendations include:
For Contractors: Engage qualified vCISO or MSSP providers immediately to begin compliance preparation. Delay increases risk and reduces options as implementation deadlines approach.
For Service Providers: Invest in CMMC-specific capabilities, technology platforms, and partnership development to capture market opportunities effectively.
For Technology Vendors: Develop solutions that enable rapid scaling of compliance services while maintaining quality and reducing costs.
For Policymakers: Continue supporting CMMC implementation through clear guidance, stakeholder engagement, and recognition of the critical role that vCISO and MSSP providers play in national security.
The CMMC compliance gap represents both a significant challenge and a transformative opportunity. While the numbers—270 certified organizations versus 80,000 requiring Level 2 compliance—initially appear daunting, they also highlight the potential for innovative service delivery models to bridge this gap effectively.
Virtual CISO services and MSSPs, powered by AI-driven platforms like GetCybr's, offer the scalability, expertise, and cost-effectiveness necessary to address CMMC compliance at the required pace and scale. These models transform what could be a supply chain disruption into an opportunity for enhanced cybersecurity posture across the defense industrial base.
Success requires immediate action from all stakeholders: contractors must engage qualified providers, service providers must scale their capabilities, and technology vendors must continue innovating to support rapid market expansion. The transition from CMMC policy to procurement requirement is complete—now the focus shifts to execution, where vCISO and MSSP providers will play the decisive role in maintaining supply chain continuity while strengthening national security.
The next eighteen months will determine whether the defense industrial base successfully navigates this transition or faces significant disruption. With proper preparation and the right service delivery models, the outcome can be both compliance achievement and strengthened cybersecurity across the entire defense ecosystem.