Does your organization handle cui?
Most defense contractors don’t realize how often they come across CUI in everyday work. In two minutes, learn if your company may already handle CUI.
Executive Brief
- As of November 10, 2025, the Cybersecurity Maturity Model Certification (CMMC) is formally embedded in the Defense Federal Acquisition Regulation Supplement (DFARS).
- The Department of Defense (DoD), also known as the Department of War, can now require specific CMMC levels directly in solicitations and contract awards.
- Cybersecurity has shifted from future planning to present day performance and is now a contractual requirement.
- Manufacturers are among the most impacted due to the volume of technical data and Controlled Unclassified Information (CUI) flowing through engineering systems, production networks, and supplier chains.
Dig deeper below to learn what manufacturers should know about CMMC in 2026.
CMMC Is Now Contract Law for Manufacturers
The final rule under 48 Code of Federal Regulations (CFR) incorporates CMMC into DFARS through clauses such as 252.204.7021 and 252.204.7025. These clauses reshape contract eligibility for manufacturers in three meaningful ways:
- Contracting officers can now require a valid CMMC level before award
- Prime contractors are responsible for ensuring all subcontractors that touch CUI meet the same certification level
- Compliance must be proven through evidence, accurate documentation, and alignment with submissions in the Supplier Performance Risk System (SPRS)
Manufacturers that supply parts, components, and assemblies to the DoD will begin seeing these clauses in new solicitations and in option year renewals throughout 2026.
What Enforcement Looks Like in 2026
CMMC enforcement will continue through a phased timeline, but Phase One is already active and the effects are immediate.
Phase Two begins November 2026
CMMC Level Two third party assessments become mandatory for most contracts involving CUI. Manufacturers that rely on technical data will almost always fall into this category. Only organizations with fully implemented controls and complete documentation will be eligible for award.
Phase Three begins November 2027
CMMC Level Three begins for mission critical programs. These assessments involve the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) and require significantly deeper evidence and validation.
Full enforcement by 2028
All DoD contract actions involving CUI will require the appropriate CMMC level. Early movers will have priority access to contract opportunities while lagging manufacturers face bottlenecks in assessment capacity and remediation timelines.
Why Manufacturers Face the Highest Risk Under CMMC
Manufacturers handle some of the most sensitive CUI categories across the Defense Industrial Base. These include:
- Technical drawings
- Engineering Change Orders
- Computer Aided Design (CAD) files
- Bills of materials
- Process and material specifications
- Government furnished technical data
- Part models and design packages
Unlike typical office environments, production and engineering systems were not built with modern security standards. These environments often contain legacy equipment, shared credentials, vendor access paths, and uncontrolled storage locations for sensitive data.
The DoD considers technical data compromise a high priority threat area which places manufacturers under stricter scrutiny during CMMC assessments.
Where CUI Lives Inside Manufacturing Environments
CUI does not remain isolated to a single system. It moves throughout the manufacturing process. Common exposure points include:
- Shared engineering drives and version control repositories
- Computer Numerical Control (CNC) machines that store cached part programs
- Work instruction systems that display drawings and specifications
- Supplier portals that exchange technical data with primes and sub tier partners
- Email threads containing sensitive attachments
- Backup servers that replicate entire directories containing CUI
- Operational Technology (OT) equipment that indirectly links to enterprise networks
Every environment that stores, processes, or transmits CUI must satisfy all applicable requirements in National Institute of Standards and Technology Special Publication 800 171 (NIST SP 800-171), with any controls formally documented and justified as Not Applicable where appropriate.
The Most Common Problem Areas for Manufacturers
Several issues appear repeatedly across manufacturing assessments:
Legacy OT systems
Older equipment cannot support encryption, multi factor authentication, or detailed logging. These systems must be segmented or replaced.
Flat networks
When OT and Information Technology (IT) share a common network, the entire environment becomes in scope. Assessors expect documented segmentation.
Uncontrolled engineering repositories
Broad permissions and lack of auditability create risk. Access control must reflect least privilege.
Vendor remote access
Machine support access often lacks monitoring, logging, or session control. These gaps violate multiple CMMC requirements.
Limited or missing logging
Many production and engineering systems do not record user actions or security events. Logging deficiencies remain a top cause of Level Two findings.
These areas must be remediated before engaging a Certified Third-Party Assessment Organization (C3PAO).
How CMMC Treats Legacy OT and Industrial IoT Systems
Many manufacturing environments rely on legacy OT, Industrial Internet of Things (IIoT), and other specialized systems that cannot support full implementation of cybersecurity controls.Under the CMMC Scoping Guide, these systems are often classified as Specialized Assets when they store, process, or transmit CUI.
Specialized Assets may include:
- Operational Technology and Industrial Internet of Things devices
- Internet of Things sensors and controllers
- Government Furnished Equipment
- Restricted Information Systems
- Test and measurement equipment
These assets are not exempt from CMMC. Instead, they are handled differently during assessment.
When a system is identified as a Specialized Asset, the assessment focus shifts from technical control implementation to documentation and risk management. Organizations must:
- Document the asset in the asset inventory
- Describe how the asset is treated and managed in the System Security Plan (SSP)
- Demonstrate that the asset is governed by risk-based security policies, procedures, and practices
- Include the asset in the network diagram for the CMMC assessment scope
During a CMMC assessment, Specialized Assets are reviewed through the SSP and supporting documentation. They are not assessed against all other CMMC security requirements, provided their classification and treatment are properly documented and justified.
For manufacturers, this distinction is critical. Legacy production equipment does not always need to be replaced, but it does need to be clearly identified, controlled, and documented.
Why Scoping Is the Most Critical Step in 2026
The most successful manufacturers begin their CMMC journey by establishing a precise and defensible scope.
Effective scoping identifies:
- Which systems handle CUI
- Which networks require segmentation
- Where CUI enters and leaves your environment
- Which legacy systems must be isolated or replaced
- How to reduce the size of the CUI enclave to make compliance achievable
A well-defined scope reduces assessment complexity, limits cost, and accelerates readiness.
What Manufacturers Must Do Now
Manufacturers entering 2026 should treat CMMC Level Two readiness as an active priority, not a future requirement.
Immediate steps include:
- Reviewing solicitations and option year modifications for DFARS clause 252.204.7025
- Validating that your SPRS score reflects your System Security Plan (SSP) and Plan of Action and Milestones (POA&M)
- Conducting a full NIST SP 800-171 gap assessment
- Prioritizing remediation of access control, multi factor authentication, logging, segmentation, and configuration management
- Engaging a C3PAO early to secure an assessment window before demand increases
- Coordinating with prime contractors to align readiness with their contract obligations
Manufacturers that act now will secure their position in the 2026 and 2027 contract pipeline.
FAQs
Do manufacturers need certification now?
If your solicitation includes DFARS 252.204.7025 and you handle CUI; you must meet the required CMMC level before award.
Can a manufacturer self-assess for Level Two?
Only if the contract specifically allows self-assessment for non-prioritized acquisitions. Manufacturing programs involving technical data rarely qualify.
Can OT systems be excluded from scope?
Only if networks are segmented and the system never stores, processes, or transmits CUI. Documentation must clearly prove this boundary.
What happens if the organization fails its first assessment?
You must remediate all findings, update your SSP and POA&M, and complete a reassessment before eligibility for award.
