For decades, defense contractors submitted compliance documentation to government agencies, frequently without actually having implemented the security measures they claimed to have in place. The government’s initial approach of accepting contractor promises on good faith led to inevitable outcomes: contractors signed off on controls they had never deployed; security breaches later revealed these gaps; and the government overhauled its oversight methods.
The Cybersecurity Maturity Model Certification (CMMC) now demands independent validation from accredited lead assessors such as Tracy R. Reed. These professionals conduct on-site reviews, speak with staff members, test actual security mechanisms, and document what truly exists in the environment rather than what appears in signed paperwork. Serious enforcement only began relatively recently, even though CMMC was established more than a decade ago. For contractors who expected deadlines to shift indefinitely, the reality has proven otherwise. As Reed puts it, “If you are not compliant by now, the sooner you begin the better.”
Compliance Is Continuous Work, Not a Single Checkpoint
The most common and harmful misconception Reed encounters is the idea that after passing a CMMC assessment, the responsibility ends. This fundamentally misunderstands how CMMC operates. The framework demands ongoing security maturity, not a single-point evaluation. Contractors must continuously meet all 110 security controls for the entire duration of government work and while holding Controlled Unclassified Information (CUI).
The threat landscape does not remain constant. New vulnerabilities surface, tools and systems evolve, and attack methods advance. When these changes occur, the contractor bears the responsibility for responding, independent of assessment timing. Between third-party evaluations spaced three years apart, organizations must submit yearly self-certifications and preserve evidence of compliance, including scan reports, remediation logs, and a complete record that can be examined by assessors without advance notice.
The legal framework around this is substantially more severe than standard business audits. An auditor from a private firm may dispute commercial compliance matters in contract proceedings. However, misrepresenting security to the government can result in criminal charges against company leadership. Reed emphasizes, “The government has virtually endless capacity to pursue violations.” The implications differ dramatically, and contractors treating CMMC the same way they would treat a SOC 2 certification are significantly underestimating their exposure.
Minimal Compliance Approaches Fail When It Matters Most
Most organizations naturally want to avoid the burden of compliance programs. Reed recognizes this challenge. However, problems emerge when this desire manifests as what he terms ‘bare-minimum compliance’, where organizations technically fulfill requirements while ignoring their underlying purpose, doing just enough to pass if an auditor does not probe deeply. This approach seems logical on the surface, but it contains a critical flaw.
Adversaries do not evaluate your compliance documentation. They search for weaknesses they can exploit. A contractor that merely ticked boxes without deploying genuine security has satisfied paperwork while preserving the actual exposures. The actual objective of security is safeguarding the confidentiality, integrity, and availability of data (the CIA triad), the core principle driving any security framework, including CMMC. Cutting corners on security does not eliminate threats. Rather, it postpones the problem until it manifests in the most damaging scenario imaginable.
AI Integration Is Creating Risks Most Contractors Have Not Yet Recognized
The FY2026 National Defense Authorization Act incorporates artificial intelligence and machine learning into CMMC requirements. Most contractors are unprepared for the operational reality. Every system that handles, processes, or transmits CUI falls under the full scope of CMMC, meaning all 110 controls apply. AI systems involved in those operations are likewise in scope.
In practice, most organizations use AI through web-based platforms, ChatGPT, or externally hosted machine learning services rather than systems housed internally. None of these cloud-based AI tools meet CMMC standards. Transferring or entering CUI into these services violates requirements. According to Reed, this is not happening due to intentional misconduct. Instead, employees lack written policies preventing it, receive no instruction on why it is problematic, and do not know that company executives face accountability for what employees share with these tools to accelerate their work.
Reed observes, “Leadership typically does not realize this is occurring,” but the fact remains that “staff members routinely paste confidential materials into these systems daily.” A formal, signed policy distributed to all staff represents the essential starting point, yet most contractors have not established one. As Level 2 assessments roll out through the end of 2026 and organized cyber threats accelerate, mock assessments have transitioned from helpful preparation to critical necessity. They represent the floor, not an enhancement. In Reed’s assessment, contractors not currently prepared for or approaching readiness for a mock assessment are facing serious vulnerability.
Follow Tracy R. Reed on LinkedIn for more insights on CMMC compliance, government cybersecurity requirements, and preparing defense contractors for third-party assessment.
