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
Insider threat programs are no longer siloed inside security offices.
In 2026, insider risk sits at the intersection of cybersecurity compliance, personnel security, and contract eligibility.
Defense contractors face growing expectations to demonstrate how insider threat monitoring connects to Cybersecurity Maturity Model Certification (CMMC), access control, and cleared personnel oversight.
Programs that focus only on clearance requirements miss growing cyber and compliance risks.
Dig deeper below to learn how insider threat programs have evolved, where organizations are falling short, and what “good” looks like going forward.
Why Insider Threat Looks Different in 2026
Historically, insider threat programs were driven by clearance obligations tied to the National Industrial Security Program (NISP) and overseen by the Defense Counterintelligence and Security Agency (DCSA).
That model no longer holds on its own.
Today, insider risk includes:
- Credential misuse and privilege abuse
- Malicious or negligent handling of Controlled Unclassified Information (CUI)
- Unauthorized data transfers from compliant environments
- Behavioral indicators that overlap with cyber incidents
At the same time, CMMC assessments increasingly examine how access is controlled, monitored, and reviewed across systems that store or process CUI.
Insider threat is no longer just about people. It is about how people interact with systems.
Where Cybersecurity and Clearance Risk Intersect
Insider threat risk now touches multiple compliance domains.
Clearance programs focus on:
- Trustworthiness of cleared individuals
- Reporting obligations and adjudicative issues
- Insider threat program governance and training
Cybersecurity programs focus on:
- Least privilege and role-based access control
- Audit logging and continuous monitoring
- Incident detection and response
CMMC Level 2 requires that these areas align in practice, not just on paper.
Common disconnects we see:
- Insider threat teams lack visibility into system activity
- Cyber teams do not understand clearance-driven reporting requirements
- Access reviews are performed inconsistently or without documentation
- Behavioral indicators are not tied to technical evidence
These gaps create risk during both DCSA reviews and CMMC assessments.
What Assessors and Reviewers Are Looking For
Neither DCSA nor Certified Third-Party Assessment Organizations expect perfection.
They do expect alignment.
Strong programs demonstrate:
- Clear ownership and coordination between security, information technology, and compliance teams
- Defined processes for identifying, escalating, and documenting insider risk
- Evidence that access to CUI systems is monitored and reviewed
- Training that goes beyond annual check-the-box requirements
Weak programs rely on policy language alone.
This year in 2026, undocumented coordination is treated the same as no coordination at all.
Common Insider Threat Missteps
Several patterns consistently raise red flags.
- Treating insider threat as a standalone clearance requirement
- Assuming tools replace process and oversight
- Failing to document access reviews and follow-up actions
- Relying on intent instead of demonstrated implementation
Insider threat programs are evaluated based on outcomes, not stated goals.
Building a Defensible Insider Threat Program
A defensible program connects people, systems, and oversight.
Key characteristics include:
- Documented governance that defines roles and escalation paths
- Coordination between insider threat program leads and cybersecurity teams
- Access controls aligned with job roles and reviewed regularly
- Monitoring that produces actionable evidence
- Training tailored to both cleared and uncleared personnel
The goal is not to monitor everything.
The goal is to show that risk is understood, managed, and addressed consistently.
Why This Matters for Contract Eligibility
Insider threat weaknesses rarely exist in isolation.
They often surface alongside:
- Access control gaps
- Incomplete audit logging
- Poor separation of duties
- Inconsistent enforcement of policies
These issues affect both clearance standing and CMMC outcomes.
In a competitive environment, unresolved insider threat gaps can delay or disqualify your business from awards, increase scrutiny from primes, or create audit risk after award.
