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CMMC Compliance for Armament Manufacturers in 2026: What You Must Do Now

by Danielle Barbour updated February 5, 2026 CMMC Compliance

Reading Time: 8 minutes

With Phase 1 of CMMC implementation activated November 10, 2025, and Phase 2 launching November 10, 2026, armament manufacturers face immediate compliance requirements impacting DoD contract eligibility. The critical question: how will you achieve certification before Phase 2 mandatory assessment requirements take effect?

Executive Summary

Main Idea: CMMC Phase 2 begins November 10, 2026, requiring armament manufacturers to achieve third-party C3PAO certification for Level 2 compliance or risk disqualification from DoD contracts, with unique challenges including legacy manufacturing systems, nation-state threats, and multi-level security environments demanding immediate action.

Table of Contents

Why You Should Care: Industry reports indicate C3PAO assessment backlogs extending 6-12 months, with preparation timelines typically ranging 4-24 months depending on current security posture. Armament manufacturers who haven’t completed gap assessments and engaged assessors face compressed timelines. Major defense primes including Lockheed Martin, Boeing, and Northrop Grumman have issued supplier compliance directives, with some fiscal year 2026 contracts already including C3PAO requirements.

Key Takeaways

Phase 2 mandatory C3PAO assessments begin November 10, 2026, eliminating self-assessment options for most Level 2 contracts. Major defense primes including Lockheed Martin, Boeing, and Northrop Grumman are already demanding compliance documentation from suppliers, with some FY2026 contracts requiring C3PAO certification immediately.
Legacy manufacturing equipment processing CUI cannot implement required NIST 800-171 Rev 2 controls without significant upgrades. CNC machines, testing equipment, and quality assurance systems running Windows 7 or proprietary operating systems lack capabilities for access enforcement, boundary protection, and integrity checking mandated by CMMC.
CMMC requirements flow down to specialized subcontractors, making supply chain compliance verification a prime contractor responsibility. Heat treating, precision machining, and plating vendors accessing CUI must achieve certification before receiving work, with primes auditing sub-tiers to ensure adequate protection.
Nation-state actors from China, Russia, Iran, and North Korea specifically target armament manufacturers through sophisticated APT campaigns. CMMC controls IA-2, SI-4, and IR-4 defend against these threats only when properly implemented with continuous monitoring and rapid incident response capabilities.
Enclave strategies isolating CUI processing can significantly reduce CMMC assessment scope and costs. Network segmentation separating CUI systems from general business operations minimizes assets subject to expensive C3PAO certification while maintaining operational security for weapons programs, potentially reducing assessment scope substantially.

CMMC 2.0 Compliance Roadmap for DoD Contractors

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The Current State of CMMC Implementation in 2026

Phase 1 to Phase 2 Transition: Where We Are Now

DFARS clause 252.204-7021 became effective November 10, 2025, officially activating CMMC compliance requirements. Phase 1 (November 2025 through November 9, 2026) requires self-assessments for Level 1 and Level 2 contractors. Phase 2—beginning November 10, 2026—introduces mandatory C3PAO assessments for most Level 2 contracts.

Phase	Timeline	Requirements
Phase 1	Nov 10, 2025 – Nov 9, 2026	Self-assessments and annual affirmations
Phase 2	Nov 10, 2026 – Nov 9, 2027	C3PAO assessments mandatory for Level 2
Phase 3	Nov 10, 2027 onward	C3PAO requirements in existing contract options
Mandatory	Nov 10, 2028	CMMC clauses mandatory in all applicable contracts

Major defense primes aren’t waiting. Lockheed Martin, Boeing, and Northrop Grumman have issued supplier directives demanding immediate compliance documentation. Some FY2026 contracts already include C3PAO requirements, meaning delays equal disqualification.

Understanding the Three-Level Framework

CMMC 2.0 streamlined the original five-level model to three tiers:

Level 1 (Foundational): Federal Contract Information (FCI) only. Basic cyber hygiene aligned with FAR 52.204-21. Annual self-assessment required in SPRS.
Level 2 (Advanced): Controlled Unclassified Information (CUI). Implements 110 controls from NIST SP 800-171 Rev 2. Requires C3PAO or self-assessment every three years, plus annual attestation.
Level 3 (Expert): Most sensitive CUI. NIST SP 800-172 protection. DIBCAC assessment required.

Most armament manufacturers require Level 2 certification due to technical specifications, performance data, and design documentation.

What Armament Manufacturers Must Do Now in 2026

Immediate Actions for Non-Certified Contractors

With C3PAO backlogs extending 6-12 months and preparation timelines typically ranging from 4-24 months, immediate action is critical.

Conduct NIST 800-171 Rev 2 gap assessment. Identify which of 110 controls are implemented, partially implemented, or missing. Note: DoD mandates Rev 2, not the newer Rev 3.
Develop System Security Plan (SSP). Document your information system boundaries, security requirements, control implementations, and responsibilities. The SSP must be audit-ready with detailed evidence.
Create Plan of Action and Milestones (POA&M). Address identified gaps within strict limitations—180-day maximum remediation periods with mandatory close-out assessments. Some control categories prohibit POA&Ms entirely.
Engage C3PAO early. With 6-12 month backlogs, waiting until you’re “fully ready” jeopardizes contract eligibility. Begin conversations during preparation to secure assessment slots.
Post SPRS scores. Document CMMC status in SPRS and provide annual affirmations of continuous compliance.

Building Assessment-Ready Documentation

C3PAOs verify compliance through documentation review, interviews, and technical testing. Maintain continuous documentation—not just pre-assessment compilation. Required artifacts include security policies, implementation evidence (configuration screenshots, logs, access control lists), testing results, configuration management documentation, incident response plans with testing records, training documentation, and vendor compliance verification.

Strategic Implementation Approaches

Implement enclave strategy. Isolate CUI processing to defined boundaries, reducing assets subject to expensive certification. Careful network segmentation and access controls can significantly reduce assessment scope and associated costs.
Prioritize network segmentation. Separate CUI systems from general business networks, guest Wi-Fi, and production systems. Use VLANs, firewalls, and access control lists.
Manage vendor compliance. CMMC requirements flow down to subcontractors. Under DFARS 252.204-7021, primes must verify supply chain compliance before awarding work involving CUI.
Upgrade legacy systems. Budget for systems that cannot meet NIST 800-171 controls, particularly those running unsupported operating systems or lacking encryption capabilities.

Unique CMMC Compliance Challenges Facing Armament Manufacturers

Embedded Systems and Weapon Platforms Create CMMC Compliance Gaps

Modern weapons platforms contain embedded controllers, testing interfaces, and manufacturing equipment processing CUI-classified technical specifications. Legacy equipment presents acute compliance challenges.

CNC machines, coordinate measuring machines, and testing equipment often run Windows 7, XP, or proprietary operating systems no longer receiving security updates. These systems process program files, technical drawings, and quality data—all CUI requiring protection—but cannot easily implement CMMC controls without costly hardware modifications or replacement.

NIST 800-171 controls AC-3 (Access Enforcement), SC-7 (Boundary Protection), and SI-7 (Software Integrity) require capabilities many legacy systems lack. Continuous operation requirements compound challenges—critical equipment runs 24/7 to meet production schedules, making remediation windows nearly impossible without risking contract delivery deadlines.

Classified Environments Require Multi-Level CMMC Security

Manufacturers handling both CUI and classified information face additional complexity. Sensitive weapons programs may require Level 3 certification—NIST SP 800-172 protection significantly more rigorous than Level 2’s baseline.

Multi-level security demands compartmentalized data handling with strict separation between classification levels. Physical security for classified programs (SCIFs, secure manufacturing spaces) must integrate with cybersecurity controls. Controls PE-2 (Physical Access Authorizations) and PE-3 (Physical Access Control) extend beyond offices to production floors, test ranges, and quality facilities.

Supply Chain and Export Control Layers Add CMMC Complexity

Specialized subcontractors—precision machining, coatings, heat treating—must achieve CMMC compliance to continue receiving work. Many lack cybersecurity expertise and struggle with costs. Primes now audit sub-tiers to verify adequate CUI protection.

ITAR and EAR requirements layer onto CMMC. Controls must simultaneously address:

Classification of hardware, technical data, and technology
Need-to-know access restrictions
Detailed audit trails for export-controlled information
Data security policies meeting both CMMC and ITAR/EAR
Staff screening and training for controlled data

Technical data packages containing manufacturing specifications are both CUI and export-controlled, requiring security implementations satisfying both frameworks.

Nation-State Threats Target Armament Manufacturers for CMMC Failures

China, Russia, Iran, and North Korea conduct APT campaigns specifically targeting weapons manufacturers to steal technical data. These sophisticated actors employ long-term reconnaissance, supply chain compromises through weaker subcontractors, zero-day exploits, and social engineering.

CMMC controls IA-2 (multi-factor authentication), SI-4 (system monitoring), and IR-4 (incident handling) defend against these threats—but only when properly implemented with continuous monitoring and rapid response, capabilities many manufacturers struggle to maintain consistently.

Testing Operations Generate CUI Requiring CMMC Protection

Ballistics data, aerodynamic measurements, reliability results, and failure analysis reports contain performance specifications revealing weapon capabilities—all CUI requiring protection. Testing equipment (sensors, telemetry, data acquisition) must implement CMMC controls.

Remote testing at government ranges or specialized facilities requires consistent security across distributed infrastructure, centralized monitoring, and careful data transfer management between geographically separated locations.

Long-Term Support Extends CMMC Compliance Decades

Weapons systems remain in service 30+ years, requiring manufacturers to maintain technical documentation and manufacturing capabilities for decades. The F-15 has been in service since 1976 with ongoing support requirements.

CMMC compliance challenges include retrofitting legacy systems with modern controls without breaking functionality, managing obsolete components with secure alternatives, protecting technical data packages over extended periods as standards evolve, and securing field support systems used by maintenance personnel processing CUI.

Critical Timeline and Next Steps for 2026

Q1-Q2 2026 (Immediate Actions): Complete gap assessment to understand compliance posture and build realistic timelines. Finalize SSP documentation through multiple review cycles. Engage C3PAOs immediately—don’t wait for “full readiness.” With 6-12 month backlogs, secure Q4 2026 or Q1 2027 assessment slots now. Implement critical controls, prioritizing those with longest deployment times (MFA, SIEM, encryption) and controls enabling dependent implementations.
Q3-Q4 2026 (Assessment Preparation): Complete POA&M remediation within 180-day limits. Schedule C3PAO assessment before November 10, 2026 Phase 2 implementation. Verify subcontractor compliance throughout supply chain. Establish processes for annual affirmation and ongoing documentation maintenance.
2027 and Beyond (Continuous Compliance): Level 2 certifications are valid three years, requiring recertification before expiration. Between certifications, annual self-attestation is mandatory. Maintain continuous compliance through regular internal assessments, ongoing monitoring, and prompt gap remediation. Monitor POA&M close-out deadlines—missing them can lapse conditional certification, immediately affecting contract eligibility. Stay informed on evolving requirements through industry associations and C3PAO relationships.

The Compliance Window Is Closing: Act Now or Lose DoD Contracts

CMMC compliance is mandatory for armament manufacturers in 2026—not optional or future-focused. Phase 2 begins November 10, 2026, requiring C3PAO assessments.

The unique challenges manufacturers face—embedded systems processing CUI, nation-state threats targeting weapons developers, multi-level security environments, export control integration, decades-long support obligations—demand specialized approaches beyond generic IT security.

With 6-12 month C3PAO backlogs, manufacturers without completed gap assessments, comprehensive SSPs, and engaged assessors are already behind. Further delays risk contract loss, bid exclusion, and False Claims Act liability.

The path forward: complete gap assessments, remediate deficiencies, engage assessors early, build sustainable compliance programs. Manufacturers investing in compliance infrastructure now will secure defense supply chain positions. Those who delay face immediate consequences. The compliance window is closing. Act now.

Kiteworks Helps Armament Manufacturers Achieve CMMC 2.0 Level 2 Compliance

The Kiteworks Private Data Network, containing FIPS 140-3 Level 1 validated encryption, consolidates email, file sharing, web forms, SFTP, and managed file transfer—enabling organizations to control, protect, and track every file entering and exiting the organization.

Kiteworks supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box, accelerating accreditation for armament manufacturers through automated policy controls and cybersecurity protocols aligned with CMMC 2.0 practices.

Core capabilities include FIPS 140-3 Level 1 validated encryption, FedRAMP authorization for Moderate Impact and High Ready Level CUI, AES 256-bit encryption with customer-managed keys, comprehensive audit logging, multi-factor authentication, and granular access controls. Secure deployment options include on-premises, private cloud, hybrid, and FedRAMP VPC configurations—providing flexibility for classified program requirements.

For armament manufacturers managing CUI across complex supply chains and long-term sustainment programs, Kiteworks provides the unified platform necessary to achieve and maintain CMMC compliance.

To learn more about Kiteworks, schedule a custom demo today.

Frequently Asked Questions

CMMC Phase 2 begins November 10, 2026, requiring armament manufacturers handling Controlled Unclassified Information to achieve Level 2 certification through third-party C3PAO assessments rather than self-assessments. Phase 2 makes C3PAO assessments mandatory for most Level 2 contracts, validating implementation of all 110 NIST SP 800-171 Rev 2 security controls with evidence-driven audits every three years plus annual self-attestation.

CMMC Level 2 preparation typically takes 4-24 months depending on current security posture, with C3PAO assessment scheduling requiring an additional 6-12 months due to assessor backlogs. Armament manufacturers must complete gap assessments, develop System Security Plans, implement required controls, remediate gaps within 180-day POA&M limits, and compile audit-ready documentation before engaging C3PAOs for the multi-day assessment process.

Armament manufacturers face unique CMMC challenges including legacy manufacturing equipment (CNC machines, testing systems) running unsupported operating systems that cannot implement required security controls, weapons testing operations generating vast CUI, nation-state actors specifically targeting weapons technical data, multi-level security environments mixing CUI and classified information, ITAR/EAR export control integration, and 30+ year product lifecycles requiring sustained compliance across decades of system support.

Yes, CMMC requirements flow down to all subcontractors handling Federal Contract Information or Controlled Unclassified Information. Under DFARS 252.204-7021, prime contractors are responsible for verifying subcontractor compliance before awarding work. Specialized vendors providing heat treating, precision machining, plating, or quality testing services must achieve appropriate CMMC levels if accessing CUI, with primes auditing sub-tiers to ensure adequate protection.

A CMMC enclave strategy isolates CUI processing to defined system boundaries, reducing the number of assets subject to expensive C3PAO certification. By segregating CUI systems from general business networks through network segmentation, firewalls, and access controls, armament manufacturers can substantially reduce assessment scope, significantly lowering implementation costs, assessment fees, and ongoing maintenance while maintaining operational security for weapons programs.

Additional Resources