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It has been said for some time that there is little understanding of how the DIB, specifically the international DIB will comply with DFARS and CMMC. The DoW doesn’t know how many contractors are affected by DFARS cyber requirements globally, as many contractors did not flow down requirements, as many paid little attention to DFARS 7012 compliance.
@Thaddeus Dziekanowski we have said for many years that DFARS and CMMC compliance is a numbers game, and for the EU, DIB is going to be a problem. How many C3PAOs are EU-based, and how many CCAs and CCPs exist in the EU? How will the EU DIB comply with CMMC requirements if they are required to have a certificate of compliance?
The numbers below are important, but one suspects they do not reflect the international DIB. They will wake up to the fact that it needs to comply only when a certificate of compliance is required, or when the DoJ and DoW audit compliance. That is standard compliance practice: wait for regulatory oversight, and then comply. This, however, will not work for the DoW for 2 reasons. Contractors have been required to comply since 2017, and we are starting to see CMMC Level 1 and 2 requirements appearing on sam.gov just to access tender data.
If the figures below are correct, and lead times for certification are 2 years, then Huston (Paris, Frankfurt, Athens, Madrid, London……), you have a problem. A problem that requires a solution sooner rather than later, when it is too late.
One must also remember this. Contractors have had since 2017 to comply with the basics of CMMC. A certificate is simply an affirmation that you comply.
@Parava Security Solutions
#dfars #cmmc
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