Sum IT Up: CMMC News Roundup

AUSA Supply Chain Cyber Readiness Preview: https://tinyurl.com/AUSAsupplychain

The CIRCIA final rule has entered regulatory review, putting publication potentially just months away. For defense contractors, one major question remains unresolved: will CISA accept existing DFARS 252.204-7012 cyber incident reports, or will contractors have to report the same incident twice?

We break down why the two 72-hour reporting requirements are far less similar than they appear, what “substantially similar” actually means, and why CIRCIA could create an entirely new reporting obligation for the defense industrial base.

CIRCIA Proposed Rule: https://www.federalregister.gov/documents/2024/04/04/2024-06526/cyber-incident-reporting-for-critical-infrastructure-act-circia-reporting-requirements

CIRCIA Pod 1: https://youtu.be/bvwnNSpDZgU?si=bJjZjrhzHJQxqYKH

CIRCIA Pod 2: https://youtu.be/ngYSaO5fg5Y?si=vk-9dTSqT1HrNakq

CIRCIA Pod 3: https://youtu.be/kUdhl5QfziU?si=kEnHdlWD8D17w0Pf

Managed Service Provider (MSP) Grader: https://summit7.us/mspgrader

Congress has introduced new legislation aimed at helping small businesses navigate CMMC, promising clearer guidance, lower costs, and better federal assistance.

But then the CMMC provisions changed before the bill even left committee.

We break down what the Cybersecurity for Small Businesses Act actually requires, what it doesn't give the SBA authority to do, how the amended version differs from the original, and whether it would meaningfully change anything for defense contractors struggling with CMMC.

Press Release: https://wied.house.gov/media/press-releases/rep-wied-introduces-bill-strengthen-cybersecurity-and-reduce-costs-small

Bill tracker: https://www.govtrack.us/congress/bills/119/hr10238

CMMC L2 Suspended, Learn What This Means For You: https://summit7.us/blog/cmmc-phase-2-suspended-with-60-day-review-what-happens-next

DoD said it was conducting a 60-day review of CMMC. More than 60 days later, contractors are still waiting for answers. We break down the conflicting CMMC timelines, the additional 15-day window described by DoD CIO Kirsten Davies, what the suspension actually means today, and when we might realistically see the CMMC Reform Task Force recommendations.

July 13th memo: https://dodcio.defense.gov/Portals/0/Documents/Library/CMMC-ReformMemo.pdf

Davies (DefenseScoop): https://defensescoop.com/2026/07/17/pentagon-task-force-to-review-cmmc-hits-the-ground-running/

Rachel Tenney was working in counterintelligence and insider risk at Honeywell when she raised cybersecurity concerns involving sensitive defense technology. Years later, her False Claims Act case ended in a $2 million settlement.

In this episode, Rachel joins us to tell the story from her perspective: SolarWinds, raising concerns inside Honeywell, becoming a relator, the years-long government investigation, and what security practitioners, CISOs and defense contractors can learn from her experience.
Settlement: https://www.justice.gov/opa/pr/honeywell-aerospace-inc-agrees-pay-over-2m-settle-false-claims-act-allegations-failing
Solarwinds (GAO): https://www.gao.gov/products/gao-22-104746

Speak With Our Team: https://summit7.us/contact



CMMC may be on hold, but cybersecurity rulemaking isn't. We break down five major requirements defense contractors need to watch, including the FAR CUI rule, CIRCIA, DFARS 252.204-7012 updates, CMMC 3.0, and post-quantum cryptography.



FAR CUI Proposed Rule: https://www.federalregister.gov/d/2026-12559/p-116



FAR CUI pod: https://youtu.be/l7BHnTdD9yM?si=7LQJ9LDup4LoJaCr



CIRCIA: https://www.regulations.gov/docket/CISA-2022-0010



CIRCIA pod: https://youtu.be/bvwnNSpDZgU?si=PvyO3JaXJJFWJFRi



CMMC 3.0: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0790-AM01



DFARS 7012: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0750-AM24



PQC: https://youtu.be/6zqaXGhP7SE?si=jefs2Pbjm_sPknnV