Why CMMC Readiness Is a Revenue, Risk, and Leadership Decision
Marissa Pederson
October 6, 2026
The cybersecurity landscape within the defense contracting sector has undergone significant changes, particularly with the introduction of the Cybersecurity Maturity Model Certification (CMMC). This certification has evolved from a prospective concern to an urgent operational reality that defense contractors must address. The Department of Defense (DoD) has officially initiated the phased implementation of CMMC requirements, with the first phase commencing on November 10, 2025, and concluding on November 9, 2026. This initial phase focuses predominantly on self-assessments for CMMC Levels 1 and 2, emphasizing the necessity for compliance among organizations handling Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
While many organizations mistakenly delegate CMMC compliance primarily to IT or security teams, the implications and responsibilities extend far beyond technical departments; they resonate at the highest levels of leadership. Skip Chapman, director of government programs at Fortra, succinctly argues that the decision regarding CMMC compliance should be viewed not merely as a technical requirement but as a fundamental business decision. He highlights, "If your company handles FCI or CUI data, you must be CMMC compliant or risk the loss of all your DoD business."
This perspective encourages organizations to frame their approach to CMMC around key business elements such as current DoD revenue, potential future contracts, expectations from prime contractors, and the financial implications of losing eligibility. Crucially, the impact of CMMC extends to non-DoD federal agencies—including civilian agencies—that are increasingly incorporating CMMC language in their contracts. Essentially, the obligation to safeguard Federal controlled unclassified information is broadening and now includes subcontractors, research institutions, and even state and local governments.
The CMMC framework was designed to assess the compliance of defense contractors in relation to safeguarding requirements for federal contract information and CUI. This systematic evaluation aims to provide enhanced assurance that contractors adhere to necessary cybersecurity standards. Notably, CMMC requirements will be integrated into contracts, mandating that both DoD contractors and subcontractors achieve a specific level of CMMC compliance as a requirement for contract awards.
Positioning CMMC as a Leadership Concern
Given its sweeping ramifications for business continuity and growth, CMMC readiness must not be relegated to IT departments alone; it is unequivocally a leadership issue. Organizations that rely heavily on DoD revenue or support prime contractors, as well as those handling controlled technical information or aspiring to grow within the defense industrial base, must recognize that CMMC readiness is inherently tied to their operational viability.
To appropriately elevate the conversation around CMMC compliance, executives should approach it from a standpoint of revenue risk rather than viewing it as merely an IT checklist. A misguided framing of CMMC as a technical obligation can lead organizations to underfund initiatives critical for compliance. While technical controls are certainly part of CMMC, the program impacts far more than just IT—its reach extends into contracts, sales strategies, legal obligations, procurement practices, human resources, operational workflows, and even customer relationships.
Instead, the executive dialogue around CMMC should initiate with a focus on revenue stakes. Important queries that should guide discussions include: How much of current revenue is derived from DoD and civilian contracts? What portion of this is indirectly generated through prime contractors? Which contracts involve FCI or CUI, and what future bids will require CMMC compliance? Additionally, organizations should assess how much revenue could potentially be lost if they do not achieve compliance.
As pointed out by Marc Zurcher, managing principal at Coalfire, prioritizing revenue is crucial for organizational sustainability. He emphasizes, "A business is there to make money… At the end of the day, if you can’t make money, it can’t survive."
Understanding CMMC Levels and Compliance Costs
The tiered structure of CMMC reflects varying levels of sensitivity concerning different types of information. At a high level, Level 1 is focused on baseline safeguarding of FCI, while Level 2 applies to those handling CUI and aligns with NIST SP 800-171 Revision 2 requirements. Level 3 caters to higher-risk programs that necessitate enhanced requirements tied to NIST SP 800-172. Executives do not need to understand every technical control associated with these levels, but they must be aware of which level pertains to relevant business opportunities.
Cost considerations also play a significant role in planning for CMMC compliance, where the scope of CUI exposure within an organization can dramatically affect compliance expenses. Organizations spread thin across multiple systems, users, and vendors face a steeper compliance burden than those that manage sensitive information within a well-governed environment. As per 32 CFR 170.19, the assessment’s scope must be specified prior to any evaluation. Simply put, early investment in a thorough CUI discovery process can significantly influence long-term costs.
Risks of Delayed Compliance
Organizations that procrastinate on CMMC readiness face a multitude of risks, including lost eligibility for contracts, delayed awards, heightened remediation costs, and increased pressure from prime contractors. Furthermore, many prime contractors may demand compliance before official timelines dictated by the DoD, emphasizing that readiness can become a competitive requirement.
The overarching goal of CMMC is to fortify the cybersecurity posture of the defense industrial base and protect sensitive DoD information in an increasingly volatile threat landscape. Given this context, CMMC should be perceived not as bureaucratic paperwork, but as a critical evolution toward safeguarding the integrity of defense-related information.
Building a Strong Business Case for CMMC Compliance
Developing a robust organizational strategy for CMMC should encompass several essential components, including an assessment of revenue exposure, contract applicability, required compliance levels, and any existing gaps in readiness related to data discovery and controls. Companies should also outline estimated budgets for compliance initiatives, as well as timelines and potential risks associated with delays.
Ultimately, CMMC readiness should be framed as an opportunity for organizations to align their strategic objectives with critical compliance goals. Fortra advocates for an integrated approach that synthesizes CMMC readiness with actionable business outcomes, enabling executive leadership to navigate the requirements effectively and ensuring that organizations can protect their revenue streams against evolving cybersecurity threats.
To catalyze meaningful discussions and enact strategic decisions, leaders should employ a systematic checklist that identifies current DoD revenue, outlines necessary compliance levels, appoints executive sponsors, defines cross-functional roles, and tracks milestones toward readiness. Through this collaborative approach, organizations can proactively prepare for CMMC compliance while simultaneously safeguarding their operational future.