What every small defense contractor must understand about CMMC scope, proof, and assessments before Phase 2
The Department of Defense has released updated guidance that quietly but significantly – clarifies how CMMC assessments will be interpreted as enforcement tightens. In January 2026, the DoD Office of the Chief Information Officer published CMMC Frequently Asked Questions, Revision 2.2, adding new answers around assessment scope, encryption, enclaves, enterprise networking, and hard-copy CUI.
For 1–25 employee defense contractors, this update is not just informational. It is a signal. As Phase 2 approaches, assessors will rely less on assumptions and more on verifiable design, documentation, and evidence. And many of the shortcuts small teams believed were “good enough” are no longer supported by official guidance.
The Real Risk in 2026 Isn’t Confusion - It’s False Assumptions
Small defense contractors already juggle contracts, operations, production, and IT. Compliance planning often happens in the margins. As a result, many organizations have leaned on simplified interpretations, such as:
As a result, many organizations have leaned on simplified interpretations, such as:
- “Encryption alone keeps systems out of scope”
- “Enterprise networking doesn’t matter if the enclave has no internet”
- “Paper CUI means we don’t need to worry about assessments”
- “We’ll fix documentation later”
Assessments - What the January 2026 FAQs Clarified
The January 2026 update to the DoD’s official CMMC FAQs added new clarification to Section C (Assessments) – an area that frequently causes confusion during Level 2 readiness and third-party reviews.
C-Q10: Are CMMC assessments required for organizations that only handle hard-copy CUI?
No. Organizations that only handle paper CUI are not required to complete a CMMC assessment. However, the moment that CUI is scanned, photographed, emailed, uploaded, or otherwise placed onto an IT system, CMMC assessment requirements apply.
What this means:
Paper-only workflows remain out of scope, but most organizations unknowingly bring CUI into scope through routine IT use.
C-Q11: Can encryption alone create logical separation for a network within a CMMC assessment scope?
No. The DoD explicitly states that encryption by itself does not establish logical separation. While encryption protects confidentiality, it does not prevent data flow or enforce network boundaries.
What this means:
Firewalls, VLANs, routing controls, and enforceable network boundaries are still required to demonstrate proper scope separation.
C-Q12: Are enterprise networking components part of an enclave’s assessment scope if the enclave has no direct internet connection?
No – provided proper logical separation exists. If an enclave is logically separated from the broader enterprise network, encrypted CUI transmission alone does not extend assessment scope to enterprise networking components.
What this means:
Architecture matters. Proper design and documentation can prevent unnecessary scope expansion — but assumptions without evidence will not hold.
Meanwhile, your competitors are quietly partnering with MSSPs and moving faster toward readiness.
CMMC Enforcement: The Timeline Hasn’t Changed
The DoW timeline remains firm.
Phase 1
- November 10, 2025 – November 9, 2026
- Level 1 and Level 2 self-assessments and affirmations in SPRS are permitted as conditions of award.
Phase 2
- Begins November 10, 2026
- Level 2 third-party assessments conducted by C3PAOs become far more common for contracts involving CUI.
Contractors who wait to validate scope, documentation, and evidence until late 2026 will face assessor backlogs, remediation pressure, and missed contract opportunities.
The Hard Truth: Many “Mostly Ready” Environments Will Fail in Phase 2
For small contractors, CMMC failure rarely comes from missing tools. It comes from:
- SSPs that don’t match the environment
- Undefined or poorly documented scope boundaries
- Incorrect assumptions about what is “out of scope”
- Evidence that exists informally but not in assessor-ready form
As guidance tightens, these gaps are no longer gray areas. They are assessment risks. Meanwhile, more prepared competitors are already validating scope, correcting architecture decisions, and building evidence aligned to assessor expectations.
How Cyber Security Solutions Helps Contractors Get Ahead of These Changes
At Cyber Security Solutions (CSS), we monitor official DoW guidance closely and translate it into practical, defensible implementation for small defense contractors.
Instead of guessing how assessors will interpret the rules, we help clients:
- Validate enclave design and logical separation
- Confirm what is truly in scope — and what is not
- Align SSPs to the real environment, not templates
- Build evidence that stands up to C3PAO review
- Prepare for Phase 2 without last-minute disruption
The goal is simple: no surprises when enforcement tightens.
CMMC Enforcement: The Timeline Hasn’t Changed
At Cyber Security Solutions (CSS), we help contractors meet exactly the level that applies; no upsells, no inflated packages, no jargon.
Our pricing is fully transparent and scales with your team size and compliance scope:
Startup Plan — $200 / month / device (Level 1)
For small business teams. Covers up to 3 devices with managed firewall, VPN, SOC monitoring, encryption, and compliance dashboard.
CSS Enclave Plan — $1,250 / month (Level 1 & 2)
For growing teams (4–10 devices) needing full Level 2 alignment and 24/7 U.S.-based SOC support.
CSS Net Plan — $2,100 / month (Level 2 readiness)
For larger organizations (11–25 devices) needing continuous monitoring, documentation management, and enterprise-level control.
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