CMMC Assessment Challenges in 2026: Insights from Experts on Trends and Pitfalls

6 days ago
3 min read

CMMC, GSA’s Adjacent Cybersecurity Framework, and More: What Defense Contractors Need to Know

In the evolving landscape of CMMC compliance, staying ahead of the requirements is essential. The latest episode of Cape Endeavors' Bytes & Brew podcast features Terry McGraw, CEO of Cape Endeavors, in conversation with Cole French, Director of Cybersecurity Services at Kratos Defense & Security Solutions. As a leading C3PAO and FedRAMP 3PAO, Kratos provides invaluable perspectives on real-world CMMC Level 2 assessments. This discussion highlights trending topics such as assessment preparation, operational maturity beyond mere compliance, and audit risks from common oversights, which align with ongoing conversations in the cybersecurity community.

The GSA Framework: A New Layer of Complexity

The episode opens with a deep dive into the General Services Administration's recent CIO-IT Security-21-112 Revision 1, released in January 2026. This framework introduces requirements adjacent to CMMC, drawing from NIST SP 800-171 Revision 3 but with distinct differences in timelines and attestation processes. French notes that GSA received significant feedback on its initial rollout, leading to planned revisions. For contractors handling both DoD and civilian federal work, this creates potential duplication without clear reciprocity. McGraw emphasizes the administrative burden, questioning unrealistic deadlines like July 2026 compliance amidst limited third-party assessment organizations. This echoes broader industry concerns about uncoordinated standards undermining program integrity.

Positive Trends in CMMC Assessments

After over a year of active assessments, French reports an overall positive trajectory. Organizations are arriving better prepared, with improved scoping and documentation. Uniform training from Cyber AB and higher throughput have contributed to this rhythm. However, gaps persist for newcomers, who often lack understanding of basic requirements despite abundant resources like webinars and podcasts. This trend reflects community discussions on the need for targeted education to bridge knowledge disparities.

The Core Challenge: Procurement Versus Security Framework Mismatch

A key focus is the structural tension in CMMC 2.0, where certifications tie to specific CAGE codes in eMASS submissions, but business realities like acquisitions introduce complications. French explains that post-assessment changes, such as integrating users from a newly acquired entity without altering the technical system, can leave uncovered CAGE codes, leading to procurement issues. McGraw adds that large conglomerates frequently encounter orphaned CAGE codes, complicating infrastructure leverage. This misalignment between technical security and federal procurement mechanics is emerging as a defining challenge, particularly as more assessments complete and operational changes occur.

Reassessment Nuances and Market Misrepresentations

The conversation addresses fears around reassessments, debunking claims that changing external service providers automatically triggers one if the environment remains unchanged. French highlights the vagueness in guidelines, creating opportunities for misinformation. Both experts warn against snake oil solutions promising quick compliance, stressing tailored approaches over one-size-fits-all methods. This aligns with calls for ethical practices and expert collaboration in the field.

False Claims Act Risks and Strategic Advice

The episode also covers rising Department of Justice Civil Investigative Demands under the False Claims Act, often stemming from whistleblower actions in historically ambiguous periods. French recommends early legal engagement to establish attorney-client privilege during assessments, mitigating discovery risks. McGraw advocates cross-departmental alignment between procurement, compliance, and security teams to avoid oversights. For organizations, consulting experienced partners is crucial to navigate these nuances effectively.

Conclusion and Advice

As the CMMC program continues to mature in 2026, the insights shared by Cole French and the experiences at Cape Endeavors make one point clear: successful compliance requires more than technical controls and a passing assessment score. It demands precise scoping, proactive management of operational and procurement changes, and a structured approach to evidence and documentation that withstands both C3PAO scrutiny and future business evolution. Organizations that treat CMMC as an ongoing operational discipline, rather than a one-time certification event, position themselves to maintain competitive advantage in the Defense Industrial Base.

To move forward effectively, defense contractors should take the following actions:

Conduct a thorough internal review of current CAGE code coverage against active and planned business entities, acquisitions, and user access patterns.
Document all operational changes (even those that appear minor) and evaluate their potential impact on existing certifications before implementation.
Engage experienced C3PAO partners and legal counsel early to establish attorney-client privilege protections during preparation and assessment phases.
Align procurement, compliance, and security teams through regular cross-functional reviews to close gaps between technical implementation and contract requirements.
Avoid quick-fix solutions and instead invest in tailored, evidence-based secure enclave environments that support repeatable compliance and long-term maturity.

Cape Endeavors specializes in designing and managing CMMC-compliant secure enclaves that address these exact challenges. Our consulting services help clients achieve Level 2 certification efficiently and maintain it with confidence as requirements and business conditions evolve.