With the activation of CMMC Phase 1 on November 10, 2025, contractors meeting Level 1 Maturity (and, in some cases, Level 2) can provide self-assessment documentation in lieu of undergoing an audit with a C3PAO. This means that every cybersecurity claim a defense contractor makes now carries the same legal weight as a cost or performance claim. 

But what does this mean for contractors in the DIB? In many cases, while it opens up plenty of opportunities to streamline compliance through self-reporting, it also opens up legal liability if that reporting isn’t accurate. 

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For years, federal visibility into large-scale cyber incidents has depended on voluntary disclosure tied to regulations. The result has been delayed response coordination and inconsistent data quality. The Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) changes that model by establishing a uniform reporting framework to provide CISA with near-real-time insight into major cyber events affecting critical infrastructure.

For security decision makers, this should be a welcome shift toward continuous, government-integrated incident reporting that will reshape governance and risk management.

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As the CMMC program evolves in 2026, following the solidification of the final rule and the timelines for required certification, the Cyber AB wrestles with the need to streamline adoption across contractors while maintaining strict rigor in compliance and audits. That’s where waivers come in. 

Now, across the DIB, executives have to decide whether these waivers are legitimate from a strategic perspective or something so niche and unreliable that they don’t expect to receive one. Understanding this balance is critical for organizations as they shape their long-term compliance and growth.

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