EXECUTIVE BRIEF
As cyber-attacks increase globally, cybersecurity regulations are increasingly emphasizing cyber incident response. DFARS, NIST, and CMMC are no exception.
Here is what defense contracts need to know about cyber incident response requirements:
Dig deeper and continue learning below!
The stakes for cybersecurity have never been higher, especially for organizations handling sensitive information for the Department of Defense (DoD). Cyber attacks against organizations in the defense sector, many of which are small to mid-sized businesses, are on the rise. In fact, roughly 80% of organizations involved in aerospace, defense, and other critical infrastructure have experienced a cybersecurity breach in the last year.
A single cybersecurity incident can disrupt operations, compromise national security, and jeopardize vital contracts—especially for smaller organizations. That’s why following a strict protocol for incident response is both a critical Cybersecurity Maturity Model Certification (CMMC) requirement and a strategic business imperative. An effective incident response plan empowers organizations to detect, contain, and recover from threats quickly, minimizing damage and maintaining mission readiness.
This guide will thoroughly examine CMMC’s incident response expectations, clarify the required maturity levels, and equip you with practical steps to develop a plan that safeguards your competitive edge and operational integrity.
The scope of incident handling under CMMC depends on your certification level, which is dictated by the sensitivity of the data your organization handles.
Here’s the breakdown of the specific controls across Levels 2 and 3.
Organizations must document an incident response plan (IRP) capable of identifying, reporting, and addressing security incidents. Tasks include setting up a response team, defining clear procedures, and integrating tools for real-time monitoring and mitigation.
This control focuses on implementing mechanisms (like SIEM systems or intrusion detection tools) to monitor, detect, and report suspicious activities. Employees must also be trained to escalate anomalies promptly.
Having a response capability is one thing, but executing it is another. Organizations must demonstrate its IRP has been tested using tabletop exercises, simulated attacks, and audits to ensure the plan works as intended under real-world conditions. This proactive evaluation identifies vulnerabilities in your response system.
To ensure your organization has the ability to monitor and defend against cyber-attacks on an ongoing basis, implementing and maintaining a SOC is key to protecting your business and your sensitive information. Your SOC can be established in-house or can be outsourced to a third-party vendor.
Equipping your business with the appropriate software and hardware is the first step, but now you need a team of experts who can assess, document, and respond to cyber incidents within the required time period.
Under CMMC, reportable incidents include any event affecting the confidentiality, integrity, or availability of FCI or CUI. Some common reportable incidents are:
Be sure to report incidents to the DoD within 72 hours as required by DFARS 252.204-7012.
Each organization must define roles and responsibilities clearly to handle incident response effectively. Typical roles include:
Smaller organizations—without dedicated IT or security teams—can outsource to Registered Provider Organizations (RPOs) specializing in CMMC compliance. ISI, for instance, offers comprehensive incident response management tailored for DoD contractors.
To build a compliant Incident Response Plan (IRP), you need to focus on the following five components.
Your IRP should start with a formal policy outlining your approach to identifying and mitigating cyber incidents. This policy should align with NIST guidance and include provisions for roles, response goals, response processes, and mitigation timelines.
Implement robust real-time monitoring systems to detect intrusions, unauthorized access, or malicious activity. Your tech stack should include email security tools, firewalls, and behavioral anomaly detection. Regular training should empower employees to spot and report social engineering tactics like phishing.
Create a step-by-step playbook for responding to various types of incidents (e.g., ransomware, malware, unauthorized access). This should include containment, forensic investigation, eradication of the threat, and restoration of affected systems.
Once an incident has been resolved, conduct a detailed review with all team members involved. Focus on answering questions like:
CMMC requires regular incident response testing of your capabilities. By conducting tabletop exercises and simulated breaches, you can identify weaknesses, validate procedures, and ensure readiness.
Under DFARS 252.204-7012, DoD contractors must report cyber incidents affecting CUI or FCI to the Defense Industrial Base Cybersecurity (DIBNet) portal within 72 hours. Organizations must also preserve forensic data for at least 90 days for potential follow-up investigations. The reports should include a detailed account of the incident timeline, affected systems, and mitigation measures taken.
For small businesses with limited IT budgets or expertise, implementing CMMC-compliant organizational incident response capabilities may seem daunting. However, there are strategies to simplify the process, including:
Achieving CMMC compliance is complex, but ISI can make it manageable. With nearly 15 years of experience assisting DoD contractors, we’re uniquely positioned to help you build a robust CMMC-compliant incident response plan.
Our services include developing incident response strategies, conducting risk assessments, and effectively training your team to handle cyber threats. Whether you’re at Level 1 or preparing for Level 3, we have the resources and expertise you need.
CMMC 2.0 consolidated the model into three levels. Level 1 requires basic safeguards, while Levels 2 and 3 mandate robust incident response procedures, including comprehensive detection, reporting, and post-incident analysis.
Incident response plans should be tested at least annually, with additional tests after any significant system changes or incidents.
The responsibility typically lies with an Incident Response Team (IRT), overseen by the CISO or equivalent role. Outsourcing to an RPO like ISI can also fulfill these responsibilities.