Deciphering the CMMC Program: Understanding the DoD Proposed RULE-MAKING on Cybersecurity Standards for Defense Contractors

The U.S. Department of Defense (DoD) issued proposed regulations for the Cybersecurity Maturity Model Certification (CMMC) Program on December 26, 2023. The objective of the CMMC Program is to validate that the defense industrial base has implemented the necessary security measures to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). The framework incorporates a hierarchical structure for cybersecurity standards, evaluation prerequisites, and contractual implementation, wherein certification levels differ in accordance with the level of sensitivity associated with the data being managed. The document specifies the critical dates associated with the proposal and the procedure for providing comments. Additionally, it delineates the historical progression of the CMMC Program, the precise criteria that distinguish distinct tiers of CMMC certification. The document solicits feedback from the public on multiple facets of the proposed Cybersecurity Maturity Model Certification (CMMC) Program regulations. Prominent aspects that warrant commentary encompass:

1. The proposed rule in its entirety and its ramifications.

2. The guidance detailed in the appendix materials.

3. The document specifies the requirements for information collecting.

The aforementioned domains encompass the extensive range of activities associated with the CMMC Program, such as its execution, evaluation systems, and the distinct criteria at various CMMC tiers.

The proposed rule-making can be found at: https://www.federalregister.gov/documents/2023/12/26/2023-27280/cybersecurity-maturity-model-certification-cmmc-program or the document can be downloaded here.