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A Simple Guide to CMMC/ DFARS 7012 Compliance
A Simple Guide to DFARS/ CMMC, NIST SP 800-171 and Compliance
DFARS/ CMMC, NIST SP 800-171 and Compliance
Weapon System cybersecurity protects the mission and the warfighter, and for companies across the Defence Industry Base (“DIB”), cybersecurity compliance, more specifically compliance with CMMC (DFARS 252.204-7021) and NIST SP 800 171 (“NIST 171”), should be on the corporate radar. Compliance with NIST 171 has been a formal requirement for contractors and subcontractors who are covered under DFARS 252.204 – 7012 (“DFARS 7012”) since December 31st, 2017. Requiring contractors and subcontractors to self-attest to their compliance with the required 110 NIST cybersecurity practices.
On the 10th of September 2025, the Department of War (DoW) issued a Final Rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to embed contractual requirements under the Cybersecurity Maturity Model Certification (CMMC) program—partially implementing Section 1648 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020. Further strengthening how the DoW assesses contractor cybersecurity practices and safeguards sensitive unclassified information across its industrial base.
The DoW has clarified that compliance with CMMC and NIST SP 800-171, while not a foregone conclusion, should not be considered a new request for contractors and subcontractors covered by DFARS 252.204-7012. For covered entities, it has been a contractual requirement since 2017.
DFARS/ CMMC, NIST SP 800-171 and Compliance
In response to the increased frequency, severity, and complexity of cyberattacks, and the impact that cyberattacks pose to national, societal, and corporate security, various nation-state regulators are moving to impose cybersecurity risk management regulations. Regulations include EU NIS 2.0, DORA, the EU Cyber Resilience Act (CRA), the U.S Securities and Exchange Commission (SEC) cyber regulation, NYDFS, the UK Cyber Resilience Bill, the US Department of War CMMC program, and the UK Ministry of Defence Cyber Security Program.
Cyber regulations set out a range of requirements for covered companies to implement and demonstrate cybersecurity, cyber risk Management, Board Governance, oversight and assurance over cybersecurity risks, or face a range of enforcement that include censure, corrective orders, market bans civil or criminal penalties, contract exclusions. Increasing board accountability, responsibility, legal and compliance risk.
Board Governance of cybersecurity risk is a critical tool boards are required to adopt to ensure that they can demonstrate oversight and assurance of cybersecurity risk.