CMMC isn’t an IT Project - It’s a Business Strategy

If you’re a defense contractor, CMMC has been on the horizon for a while. In 2026, it’s no longer “coming soon.” It’s becoming a condition of doing business.

Where companies get sideways is treating CMMC like a technical cleanup effort for IT. IT is involved, but CMMC doesn’t live in the server room. It lives in contracts, workflows, and day-to-day behavior across the business.

The legal reality: DFARS 252.204-7012

Before you talk tools, you have to talk obligations. If you do work with the DoD (or you’re in a supply chain that supports it), you’ve probably signed contracts with DFARS 252.204−7012. That clause has required contractors to provide “adequate security” and implement NIST SP 800-171 requirements for years.

CMMC is the enforcement mechanism that validates whether you actually did what DFARS 7012 required. DFARS is the commitment; CMMC is the third party verifying it. If you’ve been signing 7012-covered work without treating 800-171 seriously, the exposure isn’t just an IT inconvenience—it can become a contract, legal, and revenue problem.

The “hidden” CUI: you create more than you think

A lot of businesses assume CUI is only the data the government sends them, already labeled and packaged. That’s not how it typically plays out.

In practice, contractors often generate CUI as part of performing the work. Engineering outputs are the obvious example: requirements become designs, drawings, models, and build packages. Manufacturing produces inspection records and test results. Program teams generate status reports, deliverable drafts, and technical correspondence. Even if none of it arrives with a CUI banner across the top, it can still be covered once it meets the definition in your contract and the CUI rules flowing down through it.

If your approach to CUI depends on someone else clearly marking everything for you, you’ll miss a lot of what actually needs protection.

The real stakeholders aren’t in IT

Once you accept that protecting CUI is a business process, the org chart changes. CMMC touches anyone who handles contract data, supports production, controls facilities, or creates records that prove you followed your own rules.

Shipping & Receiving: Physical protection isn’t abstract. If sensitive paperwork, media, or labeled parts sit unattended or move through uncontrolled areas, that’s a compliance issue.

Sales & Business Development: Early-stage specs and drawings often show up during quoting and proposal work. If those files land on personal devices, personal email, or unmanaged storage, you’ve already created a problem before the PO even exists.

Engineering & Design: These teams produce large volumes of derivative technical data. They need clear rules for where it lives, how it’s marked (when required), how it’s shared, and how changes are tracked.

Maintenance & Janitorial Staff: Physical access matters. If people can wander into areas where CUI is displayed, stored, printed, or discussed, “policy” won’t save you during an assessment.

Executive leadership: CMMC doesn’t allow leadership to treat security as a side quest. If leadership doesn’t fund it, enforce it, and back it when it slows someone down, assessors pick up on that quickly.

Marketing: This gets overlooked until it’s too late. Photos and videos can capture drawings, screens, part markings, traveler packets, and whiteboards. A single post can turn into a reportable incident.

Documentation is the common denominator

CMMC is evidence-driven. It’s not enough to say “we do that.” You have to show it.

That means policies, yes—but also proof: access reviews, training records, visitor logs, incident response artifacts, change tickets, screenshots, meeting notes, sign-offs, and retained communications. Every department that touches CUI should understand what records they’re expected to produce and where those records live. The companies that struggle aren’t always the least secure; they’re often the least consistent at documenting what they do.

The Strategy: Effective Resource Management

Compliance is expensive, both in terms of money and man-hours. To avoid burning resources, you need a lean strategy:

Scope Small, Think Big: Don’t try to certify your entire company if only 10% of your staff handles Controlled Unclassified Information (CUI). By “enclaving” your data—creating a specific, locked-down environment for defense work—you can drastically reduce the number of devices and people that need to meet the high-level CMMC standards.

Gap Assessment First: Don’t buy new software yet. Use your existing resources to see where you already stand. You might find you’re already 60% of the way there just by turning on features you already pay for in Microsoft 365 or Google Workspace.

Continuous Monitoring vs. One-Time Project: The biggest waste of resources is treating CMMC like a final exam you “cram” for. If you don’t build it into your daily operations, you’ll spend twice as much fixing it when the next audit rolls around.

Finding the right talent: internal vs. external

In 2026, the skills gap is real, so the staffing model matters.

Internal: Your best asset might not be your IT lead, but your most meticulous Project Manager. These individuals can be upskilled into CMMC Certified Professionals (CCP) to maintain your “compliance posture” year-round.

External: If you bring in help, look for people who work in the CMMC ecosystem (and can translate requirements into assessor-ready evidence). A general IT firm can harden systems, but CMMC success depends on scoping, boundary decisions, evidence quality, and how well your procedures match reality. A CMMC-qualified professional knows the specific dialect of the DoD and what an auditor will demand to see.

The Competitive Edge: Why Bother?

While the hurdles are high, the benefits are real. Beyond just “keeping your contracts,” CMMC-compliant businesses are seeing:

M&A Value: If you ever plan to sell your business, being CMMC certified makes you a much more attractive (and less risky) acquisition.

Supply Chain Trust: Large Prime contractors are currently pruning their lists. They want to work with subcontractors who won’t get them kicked off a project due to a data breach.

Reduced Liability & Claim Success: Certification acts as a “seal of due diligence.” Reports from security firms like BitLyft indicate that businesses adhering to advanced standards like CMMC are significantly less likely to face liability claims following a breach, as they can demonstrate they met rigorous, federally mandated protocols. Furthermore, having these controls in place reduces the risk of insurance claim denials, which often occur when an organization fails to maintain the “adequate security” promised in their policy.

Bottom line

CMMC is becoming the baseline for staying in the defense market. Treat it as a business system: define where CUI lives, build repeatable processes around it, train the people who actually touch it, and collect evidence as you go. That’s what keeps assessments predictable—and keeps contracts from stalling at the finish line.