Subcontractor Survival: Meeting Prime Contractor CMMC Requirements

The cybersecurity landscape for the defense industrial base (DIB) has shifted. With the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) 2.0 moving swiftly toward full enforcement, subcontractors are finding themselves under growing pressure — not only from government regulators, but directly from the prime contractors they support.

The days of “we’ll wait and see” are over. Major prime contractors are now taking definitive action to enforce compliance across their supply chains. If you’re a subcontractor and not actively working toward CMMC readiness, you may already be behind — and the risk of being excluded from new and existing DoD contracts is very real.

The CMMC Mandate: What’s Changed and Why It Matters Now

CMMC was developed by the DoD to safeguard Controlled Unclassified Information (CUI) across the defense supply chain. Where earlier frameworks such as DFARS 7012 allowed for self-attestation, CMMC 2.0 introduces third-party certification for most contractors — and that represents a major operational and contractual shift.

As part of this shift, CMMC requirements will be phased into DoD contracts through 2025, with assessments already underway. But here’s the reality subcontractors must face: compliance is being enforced not just by the DoD, but by prime contractors who are required to secure their own supply chains.

In other words, if your organization handles CUI and you’re not already compliant — or showing demonstrable progress — you may soon find yourself locked out of opportunities, regardless of whether the official mandate has landed in your specific contract yet.

Prime Contractors Are Tightening the Screws

Prime contractors across the defense sector have made it clear: they are only working with subcontractors that can prove compliance or have a well-documented plan to get there. The message is simple—subcontractors that can’t show progress toward certification are being removed from consideration, even if their product or service is otherwise a great fit.

This isn’t just guidance; it’s formal policy. Many primes are embedding CMMC clauses into subcontractor agreements, specifying required certification levels (most commonly Level 2 for handling CUI), establishing remediation timelines, and reserving the right to audit or validate compliance status at any time.

Recent industry events and forums have reinforced this point. Security leaders from major primes have emphasized that waiting for the CMMC rule to be finalized is not an option. Subcontractors who haven’t started down the path toward compliance may already be too late. Contracts are being awarded based on current posture—not future intent.

Supply Chain Accountability Has Arrived

CMMC 2.0 was designed not just to evaluate the cybersecurity maturity of individual contractors, but to strengthen the resilience of the entire defense ecosystem. That includes every link in the supply chain—and prime contractors are now expected to demonstrate that their vendors meet CMMC requirements.

This expanded accountability means the risks of subcontractor non-compliance are substantial:

• Loss of contract eligibility: Non-compliant vendors may disqualify a prime’s proposal or trigger contract delays and terminations.
• Legal liability: Misrepresenting compliance posture or failing to disclose incidents can lead to violations under federal enforcement initiatives.
• Reputational harm: Trust is critical in defense contracting. Failure to vet and monitor subcontractors can damage a prime’s standing with government customers.
• Operational disruptions: Removing a key subcontractor mid-contract due to non-compliance can increase costs and jeopardize deliverables.

Subcontractor Challenges: Why Compliance Isn’t Happening Fast Enough

Despite these risks, many subcontractors are struggling to make progress — and not for lack of trying. The reality is that most small to mid-sized defense suppliers lack the internal expertise, bandwidth, or resources to fully understand and implement the requirements of NIST SP 800-171 and the CMMC framework.

Common pain points include:

• Unclear starting point: Many organizations don’t know what level of CMMC they need or how to scope their environment.
• Limited internal cybersecurity expertise: Teams are often too small or lack formalized roles for IT security and compliance.
• Documentation gaps: System Security Plans (SSPs), POA&Ms, incident response policies, and other critical artifacts are often missing or incomplete.
• Tool and control deficiencies: Multi-factor authentication, access control, logging, encryption, and other technical controls may not be fully implemented or monitored.
• Disjointed MSP support: Many subcontractors rely on managed service providers (MSPs) that don’t specialize in compliance and may not be equipped to support a CMMC readiness initiative.

While some prime contractors are attempting to guide their suppliers through the transition—sharing resources, best practices, and training opportunities—the ultimate responsibility still lies with each subcontractor to meet the necessary requirements.

One senior security executive recently described it as a “collective push,” emphasizing that large primes are supporting their partners where they can—but won’t wait for them indefinitely.

The Business Case for Acting Now

Beyond contract eligibility, subcontractors that achieve compliance early stand to benefit in multiple ways:

• Stronger positioning in competitive bids — both with primes and directly with DoD
• Faster onboarding with new partners who are pre-screening for compliance
• Reduced audit and oversight burden from primes or government entities
• Demonstrated commitment to security and data protection
• Lower long-term cost than waiting and needing to fast-track remediation later

Additionally, interim assessments — now available through authorized C3PAOs — offer a tactical advantage. Organizations that complete an interim certification now may receive up to three additional years of validity once the final CMMC rule is published. That means fewer disruptions, more time to mature controls, and a clear signal to primes that you’re ready.

How Compass IT Compliance Can Help

As a Registered Provider Organization (RPO) officially recognized by the CMMC Accreditation Body, Compass IT Compliance is uniquely positioned to guide subcontractors through their CMMC journey — from assessment and planning to documentation, remediation, and audit readiness.

We offer:

• CMMC Readiness Assessments tailored to your current environment and required maturity level
• Gap analysis against the 110 NIST SP 800-171 controls and CMMC Level 2 practices
• Development of required documentation, including SSPs, POA&Ms, and incident response plans
• Policy templates and implementation support to build or refine your security program
• Strategic guidance on scoping, timeline planning, and evidence collection
• Collaboration with your MSP or internal IT team to ensure smooth execution

Our experienced consultants work with organizations of all sizes — including those new to DoD work — to build practical, sustainable cybersecurity programs that meet CMMC requirements and integrate with broader business operations.

Whether your prime contractor is asking for a compliance roadmap, or you’re simply looking to protect your place in the defense ecosystem, Compass is here to help you get ready — and stay ready.

Conclusion: Compliance Is No Longer Optional — It’s Expected

CMMC is no longer a future problem — it’s today’s reality. And for subcontractors, the stakes have never been higher.

Prime contractors are acting now to secure their supply chains. Subcontractors that cannot demonstrate compliance or a credible plan to get there will be left behind. But for those who act, the benefits are real: continued eligibility, improved security posture, and enhanced competitiveness in the defense sector.

Don’t wait for your prime to issue an ultimatum — get ahead of it. Contact Compass IT Compliance today to schedule your CMMC Readiness Assessment and take control of your compliance path.