Who Needs CMMC Certification? 2026 Requirements For DoD Contractors

If you work with the Department of Defence(DoD) as a prime contractor or as a subcontractor or supplier, Cybersecurity Maturity Model Certification (CMMC) is now likely to be a condition of doing business or even pitching for contracts.

CMMC requirements will impact over 300,000 organizations in the Defense Industrial Base (DIB). But what exactly does that mean? And what level of compliance will your organization require? Let’s dive in and find out.

Who Does CMMC Apply To?

Broadly, CMMC applies to every organization in the DIB and any business that plans to be involved in defense work in the future (as either a prime or subcontractor) — without CMMC, federal defense work will be off limits for any organization.

CMMC applies to any organization that touches Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). If your client is a part of the DoD supply chain and your work involves touching FCI and CUI, then you will need to comply with the relevant level of CMMC certification — this applies whether you’re a prime contractor, subcontractor, managed service providers (MSP), managed security service providers (MSSP), or a supplier in the defence supply chain.

What Level of CMMC Does My Organization Need?

The three levels of CMMC, each requiring a specific CMMC assessment, are:

• Level 1 (Foundational): Includes 17 practices that focus on safeguarding Federal Contract Information (FCI). At Level 1, companies can perform a self-assessment each year and submit results directly into the DoD’s Supplier Performance Risk System (SPRS).
• Level 2 (Advanced): Includes 110 controls aligned with NIST SP 800-171 to protect CUI. Certification requires an independent assessment by a Certified Third-Party Assessor Organization (C3PAO), also known as a third-party assessment organization.
• Level 3 (Expert): Reserved for the most sensitive national security data, including more advanced controls from NIST SP 800-172 and requires direct government-led assessments. Very few small businesses will need to think about Level 3 certification.
  

The level of CMMC certification required comes down to the type of data you touch, not your company size. However, we’ve started to see more prime contractors dictate requirements to subcontractors and suppliers, so even if your contract may only touch FCI, a prime contractor could still demand that you achieve CMMC Level 2 in order to be eligible for contracts.

The vast majority of companies in the DIB will be required to work towards CMMC Level 2 and if you have ambitions to scale your defense work, it makes sense to set Level 2 as the target for your organization.

FCI vs. CUI

If you have a contract with the government, you will almost certainly interact with FCI.

FCI is defined as information provided by or generated for the government under a contract that is not intended for public release.

Protecting FCI data is the focus of CMMC Level 1.

CUI, however, is the trigger for CMMC Level 2. CUI is a broad category of information that is unclassified but still sensitive and requires significant protection. Examples of CUI include:

• Engineering Data: CAD files, specifications, and technical drawings.
• Research & Technology: Data sets from federally funded research.
• Privacy Information: PII of government personnel.
• Procurement Data: Proposals, cost data, and statements of work.

CMMC Flow-Down Requirements

As we mentioned above, more and more prime contractors are dictating CMMC requirements to subcontractors whether or not it’s strictly required. From the prime’s perspective, even if an organization only handles FCI, it’s likely easier to work with partners set up to handle CUI.

The reason? It often comes down to flow-down requirements. Prime contractors (the Lockheeds, Raytheons, and Boeings of the world) are contractually obligated to enforce CMMC requirements on their suppliers.

If a prime contractor shares CUI with your business, it’s on them to verify that you meet the CMMC requirements for that data. So primes are looking to de-risk their supply chains. If they have two vendors for a component - one who is CMMC Level 2 ready and one who is still working towards certification,  they will almost certainly choose the compliant vendor every time.

How to Reduce Your Compliance Burden

If you’re a part of the defense industry and looking at how you can achieve CMMC, my biggest piece of advice is to be strategic. The most expensive mistake companies make is trying to ensure the whole company meets CMMC standards.

If your organization is 100 people and only five are in roles that need to handle CUI, you don’t want to spend time and budget ensuring that all tech and teammates across the company are trained on CMMC and running CMMC compliant devices.

The smart move is to build a CMMC compliant enclave. Create a specific, isolated environment (like a dedicated AWS account or a separate physical server rack) where CUI lives. That means:

• Only the employees working on the DoD contract get access.
• Only that specific environment have to meet CMMC requirements
• The rest of your company operates as normal.

For more on this, check out guide on secure enclaves for CMMC.

Final Thoughts

CMMC is the new barrier to entry for the defense industry. Whether you’re a current contractor or eyeing up expansion into defense, CMMC isn’t a nice-to-have, it’s a legal requirement.

When a prime Contractor asks, "Are you CMMC ready?" and you can confidently say "Yes, we are Level 2 ready and have our SPRS score posted," the prime already knows they can trust your organization with DoD data. If you don’t have CMMC, they won’t even entertain working with you.

If you’re not already working towards CMMC compliance, you need to act now or risk losing contracts.

You don’t have to tackle CMMC alone. Workstreet can help you automate your CMMC Level 2 compliance, protect CUI, and win contracts with a complete, AI-enabled security program, backed by the only AI-powered RPO, as part of your overall CMMC program.

We’ve helped dozens of DoD contractors navigate CMMC, without losing momentum or market opportunities.

Book a call with our team here.

CMMC FAQS

Who Needs a CMMC certification?

CMMC is required by all contractors and subcontractors working with the U.S. Department of Defense (DoD) to meet specific cybersecurity requirements. If you handle FCI or CUI your contract will mandate that you meet standards of the required CMMC level.

If you’re not currently working on any DoD contract but are hoping to be eligible to pitch for DoD work (either as a prime, subcontractor, or supplier), you’ll also need CMMC compliance, just like other defense contractors.

Do Managed Service Providers also need CMMC?

If you’re a Managed Service Provider (MSPs) supporting DoD prime contractors, you must also meet CMMC requirements, as you often handle or extend client systems with CUI or FCI. Follow the steps outlined above or connect with an RPO to get the process in motion

Can I self-certify for CMMC compliance?

At Level 1 you can self-certify for CMMC compliance. Level 2 generally requires a formal audit with a C3PAO, though in certain contracts if low-priority Controlled Unclassified Information (CUI) is handled you may be able to self-certify — though this is very much the exception, not the rule.

How Often Do I Need to Renew CMMC Compliance?

Generally, CMMC certification Level 2 must be renewed every three years. However, this can be more frequent if there are changes to your organization’s security posture. Continuous monitoring, ongoing internal reviews, updated documentation, and addressing any POA&M can help maintain CMMC compliance.

What’s the Difference Between CMMC and FedRAMP?

CMMC is focused on overall cybersecurity posture for any organization handling sensitive DoD data, whereas FedRAMP is a government-wide program focused on cloud security. Learn more about CMMC vs. FedRamp here.