Sum IT Up: CMMC News Roundup

Back in January, we made seven predictions about where the CMMC ecosystem would be by the end of 2026.



Now that we're halfway through the year, we're checking the scoreboard.



In this episode:



• Level 2 certification growth

• False Claims Act enforcement trends

• Funding and compliance assistance programs

• The FAR CUI rule

• CMMC 3.0 and NIST SP 800-171 Rev. 3

• Early Level 3 activity

• What the GAO report actually found



Some predictions are looking strong. Others are too close to call. And at least one is trending in the wrong direction.



Here's our mid-year reality check on CMMC in 2026.



Register for Summit 7 Live: https://www.summit7.us/s7live



2026 Predictions (January): https://youtu.be/WxgGtKpF3_s?si=I9MfjmkBDojCRThv



GAO Report podcast: https://youtu.be/U0VhiN3qpdE?si=lD-Pbl3vyfbIMPw7



NCODE for SMBs: https://www.summit7.us/blog/ncode-contract-award



Assessment Capacity podcast: https://youtu.be/e_1FztgNCHM?si=PdpkkVk3SSa1V4-2



CIRCIA update: https://youtu.be/bvwnNSpDZgU?si=bS0ARRUfvvzLemmK

Remember CIRCIA?



The proposed rule would create mandatory cyber incident reporting requirements for more than 300,000 organizations across 16 critical infrastructure sectors, including the Defense Industrial Base.



Now CISA is holding a new round of town halls to gather feedback before issuing a final rule.



In this episode, we explain why CIRCIA isn't just another version of DFARS 252.204-7012, the seven biggest differences defense contractors need to understand, and why the upcoming town halls may be the DIB's best opportunity to influence the final rule.



Registration links for the CIRCIA Town Halls are included below.



Register for Summit 7 Live: https://www.summit7.us/s7live



CIRCIA Town Halls: https://www.cisa.gov/topics/cyber-threats-and-advisories/information-sharing/cyber-incident-reporting-critical-infrastructure-act-2022-circia



CIRCIA Proposed Rule Pod (2024): https://youtu.be/ngYSaO5fg5Y?si=VoVW54QvAzKe6r-r



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



Congressional Research Service Report (PDF): https://www.congress.gov/crs-product/R48025



CIRCIA Hearing: https://homeland.house.gov/hearing/surveying-circia-sector-perspectives-on-the-notice-of-proposed-rulemaking/

The Cyber AB brought the ecosystem together to deliver pretty exciting news during the May monthly town hall. Join us for this week's episode as we break down some of the topics a little deeper to see what it actually means for the ecosystem.



Things like:

• Has production accelerated within the ecosystem?

• Who is the new EVP of the Cyber AB?

• Who actually attends these meetings?

And so much more...Tune in to find out!

Cyber AB TH Replay's: https://cyberab.org/News-Events/Town-Hall



ISACA Website: https://www.isaca.org/



T3 Inquiries (older than 6 months): https://dowcio.war.gov/CMMC/Contact/

NIST SP 800-145: https://csrc.nist.gov/pubs/sp/800/145/final

DoD has updated the CMMC FAQs again, and the revision history doesn't tell the full story. In this episode, we break down the most important FAQ 2.3 changes, including significant changes, annual affirmations, CMMC UIDs, joint ventures, hard-copy CUI, and why the Affirming Official is one of the most important CMMC roles inside your company.



Register for Summit 7 Live: https://www.summit7.us/s7live



100 Level 2-Certified Clients: https://www.summit7.us/blog/100-cmmc-l2-certified-clients



NCODE: https://www.summit7.us/blog/ncode-contract-award



CMMC FAQs: https://dodcio.defense.gov/CMMC/



January FAQ Pod: https://youtu.be/8ZxqqH0zws8?si=m5n8WQttWsZV8n24



Paper CUI Pod: https://youtu.be/lcIaxVBjyr0?si=17LdlP92NuCGa_ph

It's milestone season in the CMMC world. Just six months into the Phased Rollout and there are 2.5x more Level 2 certifications than DoD expected. Meanwhile, a significant portion of those certs are Summit 7 clients. We now work with more than 100 Level 2 certified companies. Last but not least, Summit 7 was awarded the Army's NCODE contract to help bring secure and compliant enclaves to micro-sized defense contractors. Exciting times.



Register for Summit 7 Live: https://www.summit7.us/s7live



100 Level 2-Certified Clients: https://www.summit7.us/blog/100-cmmc-l2-certified-clients



NCODE: https://www.summit7.us/blog/ncode-contract-award