We Should Have Started This Sooner

Since our July 16 CMMC webinar, we’ve spoken with dozens of defense contractors, subcontractors, and Cloud Service Providers (CSPs) supporting the federal ecosystem. From primes to specialized SaaS vendors, the most common refrain we’ve heard is:

“We should have started this sooner.”
“I should have at least looked into it earlier.”

Let’s be clear: these aren’t unprepared businesses. These are established, trusted suppliers to the Department of Defense. But even among the experienced, there’s a growing realization that CMMC compliance is no longer optional—and time is running out.

CMMC Final Rule: The Storm Is Already Overhead

In case you missed our last alert:

On July 22, 2025, the DoD submitted the final CMMC rule to the Office of Information and Regulatory Affairs (OIRA)—the final step before the rule becomes federal law.

Once OIRA signs off—and they will—CMMC will be enforceable.
No more drafts. No more delays. No more grace.

When enforcement begins, companies that aren’t ready—whether they’re building hardware, processing CUI, or hosting government data in the cloud—will be locked out of DoD contracts.

It’s Not Too Late—But It Is Late

The biggest mistake we’re seeing?
Waiting.

Waiting for the rule to go live.
Waiting for the “right time.”
Waiting for the next contract.

What we’re hearing now—“We should’ve started this sooner”—is the voice of organizations racing to close compliance gaps while juggling day-to-day operations.

Even with the best intentions, the gap between “we meant to” and “we’re certified” can take months to close. And in some cases—especially for CSPs seeking FedRAMP equivalency or government data hosting approval under CMMC Level 2 or 3—that runway can be even longer.

Cloud Service Providers: The “We Should Have Started Sooner” Moment Is Now

If you’re a Cloud Service Provider (CSP) supporting the defense industrial base—think AWS, Microsoft, or any SaaS handling CUI—the window for getting ready is closing fast.

Many CSPs assumed that FedRAMP authorization or their customer’s compliance efforts were enough. They’re not.
FedRAMP does not replace CMMC.

While FedRAMP focuses on federal cloud security, CMMC requires that the cloud environment supporting a defense contractor’s data also aligns with NIST SP 800‑171 and is explicitly covered in the contractor’s System Security Plan (SSP). If your service touches Controlled Unclassified Information (CUI), you’re in scope.

Here’s why it’s late for CSPs now:

• Your Customers Can’t Certify Without You
  Contractors pursuing Level 2 CMMC need evidence that every cloud service they use is compliant—or they risk failing an assessment.
• FedRAMP ≠ CMMC
  FedRAMP can help, but it doesn’t automatically satisfy CMMC requirements like flow-down documentation, enclave alignment, or contractor-specific POA&Ms.
• Complexity Takes Time
  Multi-tenant SaaS platforms need months to finalize SSPs, close POA&Ms, and integrate CMMC-specific controls.
• Market Pressure Is Immediate
  Primes and DoD contracting officers are already asking CSPs for compliance proof. Those who can’t produce it will see customers migrate to providers who can.

For CSPs, the “we should have started sooner” moment is right now. Even with FedRAMP, failing to align with CMMC can block your customers—and your own ability to support DoD contracts.

What You Can Do Right Now

Whether you’re a contractor, subcontractor, or CSP, here’s where to start:

• Post your SPRS score
• Finalize your System Security Plan (SSP)
• Eliminate or tightly document every POA&M
• Review vendor relationships—especially MSPs and IaaS/PaaS platforms
• Schedule your C3PAO assessment if you handle CUI
• Align leadership on risk, budget, and timelines

Let’s Not Say “We Should’ve…” Again

CMMC is now a hard gate, and the window is closing fast.
If you haven’t started—or if your program has stalled—it’s time to pick up the pace.

At Cyber Defense Advisors, we help defense contractors and CSPs cut through the complexity and get certified with confidence. From readiness assessments to full lifecycle support, we meet you where you are and move you forward—fast.

Let’s make sure the next time you say “We should’ve…” it ends with:

“…called CDA sooner.”

Ready to Take the Next Step?

Cyber Defense Advisors is actively working with contractors and Cloud Service Providers across the U.S. to prepare for CMMC enforcement. Whether you need a readiness assessment, technical remediation, or help coordinating your C3PAO engagement—we’re here.

Don’t wait.

Contact us today and let’s make sure your next contract isn’t your last.