The aerospace sector is pivotal in driving national innovation and security by delivering essential technologies and services to the Department of Defense (DoD). In response to evolving cyber threats, the DoD has mandated the Cybersecurity Maturity Model Certification (CMMC), fundamentally transforming security requirements for all defense contractors and their supply chains.
Many consumer and industrial products (C&IP) companies mistakenly believe they are exempt from compliance, assuming, “We’re not a defense contractor.” Executive leadership should understand that the primary factor is whether Controlled Unclassified Information (CUI) is present within the organization.
Understanding CMMC and Its Reach
CMMC is a framework ensuring that contractors and subcontractors protect sensitive information, particularly CUI, through three levels:
- Level 1 – Foundational: Requires annual self-assessment for organizations handling Federal Contract Information (FCI).
- Level 2 – Advanced: Triennial third-party assessments for CUI. Aerospace firms must comply with 110 NIST SP 800-171 controls.
- Level 3 – Expert: Adds 24 additional controls from NIST SP 800-172 to protect CUI from Advanced Persistent Threats with DIBCAC-led audits for contracts with greater security needs.
Whether serving as a primary contractor or a supplier, if your company interacts with CUI, CMMC compliance is mandatory. These requirements are set to be included in new contracts beginning in fiscal year 2026 and will gradually extend to existing contracts as they renew. Initial references may appear in solicitations as early as summer 2025. The rollout follows a phased approach:
- Phase 1 (Started Nov. 10, 2025): Requires Level 1 or Level 2 self-assessments for new solicitations and contracts. The DoD may also start requiring C3PAO (third-party) assessments for some, but not all, Level 2 contracts.
- Phase 2 (Starts Nov.10, 2026): Introduces mandatory Level 2 C3PAO assessments for applicable contracts and begins Level 3 assessments for high-sensitivity programs.
- Phase 3 (Starts Nov. 10, 2027): Extends Level 2 and Level 3 assessment requirements to all applicable contracts, including option periods.
- Phase 4 (Starts Nov. 10, 2028): Full implementation; all DoD contracts (except COTS) will require the appropriate CMMC level as a condition of award.
Most Organizations Over-Scope or Under-Scope
We see two consistent mistakes in C&IP environments:
Organizations often limit CMMC Level 2 scope to engineering systems, overlooking that CUI frequently extends to:
- Email systems
- SharePoint libraries
- ERP attachments
- Backup systems
- Third-party service provider environments
Some organizations overextend CMMC Level 2 by including all systems and attempting to implement all 110 NIST SP 800-171 practices organization-wide, which leads to:
- Bloated budgets
- Unnecessary complexity and inefficiency
- Executive and end-user frustration
- Certification delays
Major Compliance Hurdles for Aerospace
Aerospace organizations encounter several significant challenges when pursuing CMMC certification, especially at Level 2:
Technical Difficulties
Meeting Level 2 standards requires significant IT infrastructure upgrades and advanced controls, including encryption and continuous monitoring. Retrofitting legacy manufacturing equipment, which is often essential to aerospace operations, can introduce cybersecurity vulnerabilities. Integrating these controls while maintaining uninterrupted production requires careful planning.
Financial Impact
CMMC certification involves considerable financial investment. While Level 1 compliance may require modest spending, Level 2 can result in six-figure costs for third-party assessments, consulting, and technology upgrades. Level 3 expenses may exceed $300,000. Smaller aerospace firms may need to reallocate resources and adjust budgets to manage these costs.
Complex Documentation
Achieving CMMC compliance requires thorough documentation for each requirement. Contractors must create robust policies and a comprehensive System Security Plan (SSP) to demonstrate control implementation. Executives are responsible for ongoing evidence collection, record-keeping, and the allocation of resources for documentation, regardless of internal capacity.
Resource Limitations
Aerospace organizations often have limited staff and cybersecurity expertise. Executives must either develop in-house capabilities or engage specialized consultants to meet CMMC requirements. Senior leadership remains directly accountable for certifying compliance to regulatory authorities.
Extended Timelines
Achieving Level 2 certification typically takes 9 to 18 months, from initial assessment to third-party audit. Executives must ensure effective project planning and resource alignment throughout the process.
Strategies for Success
To overcome compliance challenges, aerospace executives should consider the following strategic actions:
- Start with a comprehensive scoping engagement, understand what types of CUI you have, as you may have specified CUI that requires controls beyond CMMC Level 2. Understand how CUI currently flows to you, within your organization, to suppliers, and back to your prime or DIB entity. Then, determine whether it would be possible to change those flows to reduce the time, cost, and complexity of obtaining and maintaining certification. Document your CUI Assets, Security Protection Assets, Contractor Risk Managed Assets, and your Specialized Assets in your System Security Plan (SSP).
- Perform a comprehensive NIST SP 800-171gap analysis against the revised scope you defined in your SSP to identify gaps that require remediation. Never conduct a gap analysis prior to optimizing your CUI scope.
- Prioritize upgrades to legacy equipment and systems, ensuring they meet modern security requirements without sacrificing operational efficiency.
- Dedicate or outsource resources for documentation and evidence collection to meet audit standards.
- Establish a cross-functional team, including IT, operations, and executive leadership, to drive compliance and maintain accountability.
- Prepare early for third-party assessments by simulating audit conditions and reviewing readiness.
Engaging a highly experienced CMMC consulting specialized third-party assessor organizations, such as CBIZ Cybersecurity or Pivot Point, can reduce the operational burden of preparing for and maintaining your CMMC Level 2 certification.
Conclusion
CMMC compliance is now essential for aerospace firms working with the DoD. With executive leadership, targeted investment, and expert partnerships, compliance can become a competitive advantage. Proactively addressing security, financial, and operational gaps ensures regulatory compliance and positions organizations for long-term industry leadership.
If your business is seeking support to build or assess your CMMC cybersecurity program or has questions about CMMC Compliance for the aerospace sector, please contact our Consumer & Industrial Products Team.
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