The Reality Check Every Defense Prime Contractor Needs
Defense contract solicitations have already included CMMC requirements as far back as December 16, 2024, yet many prime contractors still don't understand what this means for their manufacturing partners. The reality today is stark: if your build to print manufacturer can't demonstrate CMMC compliance, you can't award them the contract.
This isn't another regulatory checkbox. The CMMC program protects DOD data on contractor systems from exploitation by U.S. adversaries. When you're developing life-saving medical devices for military applications or mission-critical aerospace components that may include EMI shielding requirements, every link in your supply chain becomes a potential vulnerability.
Understanding CMMC Requirements for Build to Print Manufacturing
The Three-Level Framework
CMMC applies various National Institute of Standards and Technology (NIST) security requirements on all defense contractors through a structured approach. Understanding which level applies to your manufacturing partners determines the compliance pathway.
- Level 1 Requirements: Contractors and applicable subcontractors must complete an annual self-assessment to verify their compliance with the 15 security requirements specified in Federal Acquisition Regulation (FAR) clause 52.204-21. This level addresses Federal Contract Information (FCI) such as purchase orders, invoices, and basic contract details.
- Level 2 Requirements: Contractors and applicable subcontractors must implement the 110 security requirements specified by DFARS clause 252.204-7012, which align with NIST SP 800-171 standards. Most build to print manufacturers handling technical drawings, specifications, or engineering data will require Level 2 certification.
- Level 3 Requirements: Contractors must meet all Level 2 requirements as well as 24 select NIST SP 800-172 security requirements. This level addresses the highest-sensitivity programs facing Advanced Persistent Threats (APTs).
What Constitutes Controlled Technical Information
As a manufacturer, you work most with a type of CUI called Controlled Technical Information (CTI). This includes technical drawings, specifications, build instructions, quality documentation, and any manufacturing data that could be used to design, produce, or operate defense systems.
Understanding the full scope of what constitutes CUI is critical for accurate compliance planning. Many manufacturers discover their CUI exposure is broader than initially assessed, leading to scope creep during implementation.
Common CUI Types in Manufacturing:
- Technical drawings and CAD files: Engineering specifications and part geometries
- Build instructions and work orders: Manufacturing processes and assembly procedures, including specialized manufacturing techniques
- Quality documentation: Inspection reports, test results, and certification records
- Contract specifications: Performance requirements and delivery schedules
The Manufacturing Partner Selection Challenge
Why Traditional RFQ Processes Fall Short
Your current supplier selection process likely focuses on price, quality, and delivery. CMMC compliance adds a fourth critical dimension that fundamentally changes the evaluation matrix.
Once implemented, prime contractors will not be able to contract with subcontractors that do not comply with applicable CMMC requirements. This creates a binary qualification criterion — either your manufacturing partner can demonstrate compliance or they cannot participate in the contract.
The Compliance Timeline Reality
CMMC compliance requires significant preparation time and investment. Most Level 2 assessments require 6-12 months of preparation with implementation costs typically ranging from $60-200K.
Many manufacturers underestimate their CUI exposure scope during initial assessments.
Technical Requirements for CMMC-Compliant Manufacturing
Information System Boundaries and Architecture
CMMC compliance requires manufacturers to clearly define which information systems process, store, or transmit CUI. This boundary definition directly impacts manufacturing operations and costs.
Enclave Implementation Benefits:
- Reduced compliance scope: Isolate CUI handling to specific systems rather than entire networks
- Lower infrastructure costs: Avoid securing non-essential manufacturing equipment
- Simplified assessments: Focus third-party evaluations on defined system boundaries
- Operational flexibility: Maintain normal operations outside the secure enclave
Legacy System Challenges
Manufacturing environments often include older control systems and specialized equipment that cannot support modern security controls. The DoD allows for "specialized assets" that fall under different rules as long as you document how you're mitigating the risk.
This flexibility is crucial for manufacturers operating CNC equipment, inspection systems, or other specialized tools that may run on legacy operating systems. However, documenting compensating controls requires sophisticated risk assessment capabilities that many manufacturers lack internally.
Read our guide to working with custom manufacturing partners.
Assessment and Certification Process
Self-Assessment vs. Third-Party Assessment
Basic protection of FCI will require self-assessment at CMMC Level 1\. General protection of CUI will require either third-party assessment or self-assessment at CMMC Level 2\.
The assessment type depends on the specific contract requirements and CUI sensitivity. Level 2 contractors and subcontractors that must be assessed by a third party must be certified by a third-party assessment organization (C3PAO) every three years and affirm continuous compliance annually.
Plans of Action and Milestones (POA&Ms)
Contractors are now allowed to submit POA&Ms for certain non-compliant items, providing additional flexibility in achieving certification. However, the Proposed Rule would establish a 180-day deadline for closing out any outstanding POAMs.
This limited flexibility means manufacturers must have concrete remediation plans for any security gaps identified during assessment.
Physical Security Requirements for Manufacturing
Facility Access Controls
One of the most apparent CMMC compliance and cybersecurity deficiencies we observe among manufacturing clients is the lack of physical protection of FCI and CUI. Commonly we find that buildings' outside doors remain unlocked, or as often is the case in warmer climates, propped wide open during operational hours.
Manufacturing environments present unique physical security challenges. Large bay doors, material handling requirements, and multi-building operations complicate access control implementation. Advanced manufacturing processes often require specialized equipment and materials that must be protected under CMMC requirements.
Security Domain | Level 1 Requirements | Level 2 Requirements | Level 3 Requirements |
Access Control | Basic user authentication | Multi-factor authentication, role-based access | Enhanced authentication, privileged access management |
Data Protection | Basic safeguarding of FCI | Encryption of CUI at rest/transit | Advanced encryption, key management |
System Monitoring | Basic incident logging | Continuous monitoring, audit trails | Advanced threat detection, behavioral analysis |
Physical Security | Basic facility protection | Controlled access, visitor management | Enhanced physical controls, environmental monitoring |
Assessment Type | Annual self-assessment | Third-party assessment (C3PAO) every 3 years | Government assessment (DIBCAC) every 3 years |
Document Control Requirements
Manufacturing operations require robust document management to maintain CMMC compliance throughout the production lifecycle.
Critical Control Points:
- Secure printing: FIPS-compliant transfer methods for CUI documents
- Physical storage: Locked containers for printed technical drawings and specifications
- Access logging: Tracking who accesses CUI materials and when
- Disposal procedures: Secure destruction of obsolete or damaged CUI documents
Quality System Integration with CMMC
Documentation and Process Controls
CMMC requirements align well with established quality management systems. Organizations with robust ISO 9001 or AS9100 implementations often find their existing documentation processes provide a foundation for CMMC compliance.
The key integration points include:
- Configuration management for technical documents
- Change control processes for CUI-containing drawings
- Audit trails for document access and modification
- Incident reporting and corrective action procedures
Measurement and Monitoring Systems
Quality systems' emphasis on measurement and continuous improvement directly supports CMMC's requirement for ongoing compliance monitoring. Modern quality management systems can be configured to track security-related metrics alongside traditional quality indicators.
Evaluating Manufacturing Partner Readiness
Assessment Criteria | CMMC Compliant Indicators | Risk Factors |
Information Systems | Documented CUI boundaries, encrypted storage, access controls | Shared networks, legacy systems without security controls |
Physical Security | Badge access, secured printing, visitor management | Open facilities, uncontrolled document storage |
Personnel Security | Background checks, security training, access reviews | Unrestricted facility access, minimal vetting |
Incident Response | Documented procedures, 72-hour notification capability | No formal incident response, unclear reporting |
Assessment Status | Current certification or clear compliance timeline | No assessment plan, unrealistic timelines |
Due Diligence Questions for Manufacturing Partners
Technical Infrastructure:
- How is CUI segregated from other business systems?
- What encryption standards are implemented for data at rest and in transit?
- How are user access permissions managed and monitored?
Operational Procedures:
- What processes ensure CUI marking and handling throughout manufacturing?
- How are printed materials controlled and secured?
- What incident response procedures are in place?
Compliance Status:
- What is your current CMMC assessment status and timeline?
- How do you maintain continuous compliance monitoring?
- What documentation can you provide regarding security controls implementation?
The Vertically Integrated Advantage
Risk Reduction Through Consolidation
Affected contractors should be assessing their current compliance with existing cybersecurity controls and preparing for the full set of CMMC compliance requirements before they become effective.
Working with a vertically integrated manufacturing partner reduces the number of entities in your CMMC compliance chain. Each additional subcontractor or vendor introduces compliance risk and audit complexity.
Integration Benefits:
- Single point of CMMC compliance verification
- Reduced data transfer between non-compliant systems
- Streamlined audit and assessment processes
- Consistent security controls across all manufacturing processes
Process Capability and Compliance
CMMC-compliant manufacturers must demonstrate both technical capability and security maturity. The most effective partners combine:
- Advanced manufacturing processes under controlled environments
- Robust quality management systems with security integration
- Engineering teams capable of design for manufacturability reviews
- Established relationships with certified assessment organizations
- Specialized material capabilities for defense applications
Timeline and Implementation Strategy
Phased Rollout Schedule
The DoD will gradually introduce these requirements through a phased rollout, starting with high-priority contracts in fiscal year 2025. Full implementation across all applicable contracts is expected by 2028.
This timeline creates urgency for manufacturer selection. Your organization, for example, could be far down the supply chain from a contractor subject to CMMC in Phase 1, in which case that contractor must flow down CMMC requirements to your organization at that time.
Preparation Recommendations
Immediate Actions (Next 90 Days):
- Inventory current manufacturing partners' CMMC status
- Identify contracts requiring CMMC-compliant suppliers
- Begin qualification of compliant manufacturing alternatives
Short-term Planning (3-6 Months):
- Conduct detailed supplier risk assessments of critical manufacturing partners
- Establish compliance verification procedures for new suppliers
- Update supplier qualification and audit processes
Long-term Strategy (6-12 Months):
- Transition to CMMC-compliant manufacturing partners
- Implement ongoing compliance monitoring procedures
- Develop contingency plans for supplier compliance failures
Making the Smart Choice: Your CMMC-Compliant Manufacturing Partner
The CMMC landscape fundamentally changes how defense contractors select and manage manufacturing partners. Traditional evaluation criteria of price, quality, and delivery now include a fourth critical dimension: verified cybersecurity compliance.
Smart prime contractors are moving beyond hoping their current suppliers achieve compliance. They're proactively identifying and qualifying manufacturing partners who already demonstrate CMMC readiness through robust security infrastructure, quality systems integration, and verified assessment capabilities.
When your next defense contract includes CMMC requirements, you need manufacturing partners who understand that protecting controlled technical information isn't just regulatory compliance. It's protecting the innovations that save lives and secure our nation's defense capabilities.
Ready to evaluate CMMC-compliant manufacturing partners? Look for organizations that combine technical manufacturing expertise with demonstrated security maturity, quality system integration, and the infrastructure to maintain compliance throughout your contract performance period. Because in defense manufacturing, compliance isn't optional — it's the foundation of partnership.
