More Small Defense Contractors Are Reconsidering Full GCC High Migrations

Something interesting is happening inside the Defense Industrial Base.

Long before the Department of Defense announced its review of the CMMC program, more small and mid-sized defense contractors had begun questioning whether the industry’s growing push toward full GCC High migrations was always the right answer.

The DoD’s recent decision to pause CMMC Phase II while it reevaluates the program has only added momentum to that conversation. The Department has made it clear that protecting Controlled Unclassified Information (CUI) remains essential, while also recognizing that compliance should not impose unnecessary cost and complexity on small businesses.

That raises an important question:

Are we solving the actual problem, or are we reacting to fear?

If you listened to enough webinars, sales presentations, LinkedIn “experts,” and compliance discussions, you could easily conclude that every company handling even a small amount of CUI needed to transform itself into a miniature federal agency.

For some organizations, that may be the right answer.

For many others, it probably isn’t.

Across the Defense Industrial Base are thousands of companies with fewer than 50 employees, small engineering teams, limited CUI exposure, and only a handful of users who actually access controlled information.

Yet many have found themselves being encouraged to deploy enterprise-scale architectures originally designed for organizations with dedicated Security Operations Centers, internal compliance departments, complex identity infrastructures, and multi-million-dollar cybersecurity budgets.

That’s not because these companies are resisting cybersecurity.

Quite the opposite.

Most are actively investing in multifactor authentication, endpoint protection, vulnerability management, centralized logging, employee training, documented policies, and secure collaboration.

What many are questioning is whether compliance should automatically require rebuilding their entire business around a relatively small subset of regulated data.

Should a machine shop with three engineers accessing CUI operate like a global defense prime?

Should an engineering company supporting one controlled contract inherit the complexity of a Fortune 100 enterprise?

Should a family-owned manufacturer with five enclave users have to redesign every workflow simply because the industry’s default answer has become “build everything in GCC High”?

Those are legitimate questions.

And based on the Department’s recent announcement, they’re questions policymakers are now asking as well.

The Department has stated that its review will focus on lowering barriers for small and medium-sized businesses while maintaining strong cybersecurity protections. That isn’t a retreat from security. It’s an acknowledgment that effective security and excessive complexity are not the same thing.

At its core, CMMC has always been about protecting Controlled Unclassified Information through disciplined security practices and defensible operational controls.

It was never intended to create unnecessary operational burden.

As the program evolves, one question may become more important than any other:

What is the smallest, most defensible environment we can realistically operate while still protecting CUI and demonstrating compliance?

For many organizations, that may prove to be a far more valuable design principle than assuming the most restrictive environment is automatically the best one.

The companies that succeed won’t necessarily be those that build the biggest enclaves or deploy the most complex architectures.

They’ll be the ones that can demonstrate strong security, protect CUI effectively, and do so in a way that is operationally sustainable, auditable, and aligned with how their business actually works.

That has always been good cybersecurity.

The Department’s recent announcement simply reminded the industry that it should also be good policy.

Need Help Determining the Right CMMC Strategy?

Every organization is different. The right CMMC approach depends on your contracts, your CUI footprint, your business operations, and your long-term objectives. What works for one contractor may be unnecessarily complex for another.

Cyber Defense Advisors helps organizations design right-sized CMMC environments that protect Controlled Unclassified Information, satisfy NIST SP 800-171 and CMMC requirements, and align with the realities of how their business operates. Whether you’re evaluating GCC High, Microsoft Commercial, enclave strategies, or preparing for a future assessment, our team can help you make informed, defensible decisions without adding unnecessary cost or complexity.

To learn more or schedule a CMMC consultation, contact Cyber Defense Advisors today.