Dig deeper below to learn what manufacturers should know about CMMC in 2026.
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:
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 Update
As of July 13, 2026, the Department of War (DoW) has suspended all pending and future implementation milestones in the CMMC 2.0 phased implementation plan. In short, CMMC Level 1 (Self) and Level 2 (Self) certifications are the only maturity levels contracting officers can use during this interim period. Additionally, the DoW is conducting a review of the program and will be gathering feedback on how to improve CMMC for small- and mid-sized businesses going forward. Little is known today on the future state of third-party assessments, but your current DFARS 7012 and NIST 800-171 Rev 2 obligations remain in effect.
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.
Prime contractors may require CMMC certification well before the deadline in the government's phased rollout. We keep an up-to-date record of what major primes are publicly telling their supply chains, refreshed as new guidance appears.
See what Lockheed, Boeing, and RTX are asking from manufacturers
Manufacturers handle some of the most sensitive CUI categories across the Defense Industrial Base. These include:
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.
CUI does not remain isolated to a single system. It moves throughout the manufacturing process. Common exposure points include:
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.
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).
Under the CMMC Scoping Guide, these systems are often classified as Specialized Assets when they store, process, or transmit CUI.
Specialized Assets may include:
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:
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.
The most successful manufacturers begin their CMMC journey by establishing a precise and defensible scope.
Effective scoping identifies:
A well-defined scope reduces assessment complexity, limits cost, and accelerates readiness.
Manufacturers entering 2026 should treat CMMC Level Two readiness as an active priority, not a future requirement.
Immediate steps include:
Manufacturers that act now will secure their position in the 2026 and 2027 contract pipeline.
If your solicitation includes DFARS 252.204.7025 and you handle CUI; you must meet the required CMMC level before award.
Only if the contract specifically allows self-assessment for non-prioritized acquisitions. Manufacturing programs involving technical data rarely qualify.
Only if networks are segmented and the system never stores, processes, or transmits CUI. Documentation must clearly prove this boundary.
You must remediate all findings, update your SSP and POA&M, and complete a reassessment before eligibility for award.