CMMC Business Risk Assessment Guide: Xact Cybersecurity
Update

DoD has paused the transition to CMMC Phase 2 while it reviews the program. Phase 1 and existing DFARS/NIST SP 800-171 obligations remain in effect.

For Defense Contractor Executives

CMMC Readiness Is a
Contract and Business
Risk Decision.

If a solicitation or subcontract requires a specific CMMC status, the contractor or subcontractor must meet that requirement before award or performance, as stated in the clause. Find out exactly where your business stands today.

Phase 1
In effect now. Phase 2 transition under DoD review
110
CMMC Level 2 security requirements aligned to NIST SP 800-171 Rev. 2
3
CMMC levels. The level that applies is set by your contract
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CMMC Business Risk Assessment Guide
For Defense Contractor Owners & Executives: DoD contract eligibility exposure

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The Gap Between Compliance Activity and Actual Compliance

Your IT team may have purchased tools. Your compliance lead may have built a spreadsheet. But if leadership has not made the decisions CMMC actually requires, none of that work protects your contract eligibility.

The requirements written into your contracts don't disappear because the broader program is under review. Falling short of a CMMC status a specific contract requires can affect cash flow, staffing decisions, and your standing with prime contractors.

Contract-specific certification requirements
If a solicitation or subcontract requires a specific CMMC status, the contractor or subcontractor must meet that requirement before award or performance, as stated in the clause.
Assessment type depends on the contract
The required CMMC level and whether the assessment is self-assessed or performed by a C3PAO depend on the applicable contract requirement.
CUI must be identified, not assumed
CUI should be identified through contract language, data flows, systems, and prime contractor requirements. It should not be assumed simply because an organization performs defense work.
Leadership decisions are required
CMMC is not an IT project. It requires business decisions at the owner and executive level: on scope, investment, documentation, and accountability.

Where the Program Stands Today

As of September 2026, the Department of Defense has suspended the transition to CMMC Phase 2 while it reviews the program. Phase 1 requirements and existing DFARS and NIST SP 800-171 obligations remain in effect. Contractors and subcontractors should follow the CMMC level and assessment requirement written into each solicitation, contract, or subcontract.

Inside the Risk Assessment Guide

01
Contract Eligibility Risk Framework
Evaluate how CMMC requirements map to your specific DoD contract portfolio and revenue exposure, in clear business terms.
02
Executive Decision Checklist
The critical decisions that only owners and executives can make, and why delegating them to IT creates dangerous gaps in compliance.
03
SSP & POA&M Overview
What your System Security Plan must actually reflect, and how assessors use your POA&M to evaluate what hasn't been fixed yet.
04
Assessment Readiness
What assessors evaluate and what triggers gaps: whether your applicable contract requirement calls for a self-assessment or one performed by a C3PAO.
05
Competitive Positioning
How CMMC certification becomes a differentiator in the DoD supply chain, and how to communicate it during contract pursuits.
06
Next Steps by Company Stage
Tailored action paths depending on where you stand today: from no program in place to mid-assessment to certification pending.

3 Steps to CMMC Readiness

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Assess Your Risk
Use the framework to identify gaps

Decision-Makers in the DoD Supply Chain

Business Owners
Who fund compliance programs and are ultimately responsible for DoD supply chain eligibility
C-Suite Executives
Who sign off on risk decisions and must understand CMMC as a business matter, not a technical one
Program Managers
Who manage contract pursuits and need to understand CMMC's impact on bid eligibility
Compliance Leads
Who need executive buy-in and a shared language to communicate CMMC risk upward effectively
Your Next Step

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Contract Eligibility Risk

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