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Compliance Fatigue: Why Companies Hesitate to Invest in NIST SP 800-171 and the Cybersecurity Maturity Model Certification (CMMC)

In today’s rapidly evolving cybersecurity landscape, achieving compliance with regulatory frameworks such as the Cybersecurity Maturity Model Certification (CMMC) has become increasingly critical for organizations, particularly those engaged with the Department of Defense (DoD) and its supply chain. However, despite the pressing need for robust cybersecurity measures, many companies hesitate to invest in CMMC compliance. This reluctance stems from various factors, including changing requirements, limited enforcement mechanisms, and shifting deadlines. In this blog, we’ll explore these challenges and shed light on why companies may be reluctant to prioritize CMMC compliance.

Compliance: A moving target

Many companies are fed up with what they perceive to be a moving target. While the reality is that the actual requirements for safeguarding Controlled Unclassified Information have not changed much since 2016 the rollout, education around and flow down of the requirements throughout the Defense Industrial Base has left much to be desired.  What started as 110 requirements and self-attested adherence has now evolved into 320 controls and a looming CMMC pass/fail assessment. At this point, a vast majority of organizations have entered the “wait and see” phase. Will CMMC actually become Law? Will there actually be any grace period for remediating deficiencies discovered during an assessment? Until these answers to these questions become more clear, I think the holding pattern will continue. 

Limited Enforcement

Since 2016 companies have been told that they will need to implement the NIST SP 800-171 requirements for Safeguarding Controlled Unclassified Information (CUI) or risk losing their work with the DoD. In reality, many companies, especially those further down in the supply chain, have continued getting new work without consequence. Compliance is not cheap. In fact, companies who are trying to do the right thing are often faced with having to raise their rates, making them less competitive when compared to their “non-compliant” peers. Without clear guidelines and enforcement mechanisms in place, companies who intend to do the right thing are disincentivized to invest in compliance efforts until regulatory expectations become more defined and enforcement becomes more stringent.

Sliding Deadlines

Another factor contributing to companies’ hesitancy to invest in CMMC compliance is the perception of sliding deadlines. While CMMC requirements have been outlined, the implementation timelines and deadlines for achieving compliance have been subject to adjustments and extensions. This uncertainty surrounding deadlines leads companies to postpone compliance initiatives, assuming that they have more time to allocate resources and address cybersecurity gaps. 

Resource Constraints

For many companies, investing in CMMC compliance represents a significant financial and resource-intensive endeavor. Implementing the necessary cybersecurity controls, conducting assessments, and remedying identified vulnerabilities require substantial investments in technology, personnel, and training. Small and medium-sized businesses, in particular,  face resource constraints that limit their ability to allocate sufficient resources to compliance initiatives, especially in the absence of immediate regulatory pressure or contractual requirements.

Conclusion

The challenges associated with CMMC compliance, including changing requirements, limited enforcement mechanisms, sliding deadlines, and resource constraints, contribute to companies’ hesitancy to invest in compliance efforts. However, despite these challenges, prioritizing cybersecurity and adopting proactive measures to enhance resilience against cyber threats are essential for safeguarding sensitive information, protecting critical assets, and maintaining trust with stakeholders and customers.

While the road to CMMC compliance may be challenging, the investment in cybersecurity is a crucial strategic imperative that companies cannot afford to ignore in today’s threat landscape.

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