CMMC Compliance: Key Product Development Considerations for Defense Manufacturers
Inside This Article
On November 10, 2025, the DoD’s Defense Federal Acquisition Regulation Supplement (DFARS) changes to implement the contractual requirements related to the Cybersecurity Maturity Model Certification (CMMC) 2.0 program went into effect1, making CMMC compliance mandatory for contractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). This impacts most small to midsize defense manufacturers planning to contract with the United States Department of Defense (DoD).
Under the new rule, program managers are including CMMC requirements in their solicitations and defense contracts. If your organization wants to bid on new contracts or continue subcontracting under primes, now is the time to initiate the certification process.
What Is CMMC Compliance, and Why Does It Matter?
The DoD developed CMMC as a framework to help organizations enhance cybersecurity practices throughout the defense industrial base (DIB). It originated from concerns over increasingly sophisticated cyberattacks on sensitive information across the DIB supply chain. The goal is to protect proprietary, strategic, and operational data from breaches that pose a threat to national security.
The CMMC framework impacts DoD contractors, subcontractors, and suppliers. By demonstrating compliance, organizations not only enhance data security, but foster credibility and gain a competitive advantage in the marketplace.
Navigating CMMC Certification Level Requirements
The CMMC model is centered around National Institute of Standards and Technology (NIST) and DFARS guidelines—primarily NIST SP 800-171 and DFARS 252.204-7012. Certification requirements are divided into three levels based on information type and the organization’s degree of cybersecurity maturity. The levels build upon each other. So, a Level 3 certification fulfills all the requirements of Level 2 and Level 1. Likewise, a Level 2 certification fulfills all the requirements of Level 1. Defense contractors should assess the nature of their information and cybersecurity posture to determine the level that best aligns with their business.
Level 1: Foundational – Applies to entities that handle FCI. Only basic safeguarding practices, as outlined in Federal Acquisition Regulation 52.204-21, are required for this certification. Companies must perform an annual self-assessment and attest to meeting all requirements.
Level 2: Advanced – Applies to contractors handling CUI. Here, the focus is on documentation and implementation of practices surrounding physical access controls, incidence response, risk management, and system integrity. Organizations are required to obtain third-party (C3PAO) assessments.
Level 3: Expert – Contractors handling high-priority CUI on behalf of the DoD must be certified at this level. Organizations should implement proactive measures to detect and mitigate security threats before they occur. They must also undergo government-led assessments as part of the certification.
FCI AND CUI EXPLAINED
Federal Contract Information (FCI) is not intended for public release. It is used to develop or deliver a product or service to the government.
Controlled Unclassified Information (CUI) is government-created or owned unclassified information that requires safeguarding and dissemination controls pursuant to applicable laws, regulations, and policies.
Get a Head Start to Your CMMC Certification With Arena
With CMMC and other stringent regulations at the forefront, defense manufacturers need a proven cloud-native solution like Arena to ease the financial and administrative burden of compliance and accelerate innovation.
CMMC Certification Levels
The CMMC certification levels are enforced using a four-phased approach:
- Phase 1 (Effective November 10, 2025): CMMC Level 1 or Level 2 self-assessments included in applicable contracts.
- Phase 2 (Effective November 10, 2026): CMMC Level 2 third-party (C3PAO) assessments included in applicable contracts.
- Phase 3 (Effective November 10, 2027): CMMC Level 3 assessments included in applicable contracts.
- Phase 4 (Effective November 10, 2028): Full implementation; all DoD contracts will include CMMC-level certification requirements.
Safeguarding Sensitive Product Information: Key Considerations for CMMC Compliance
Regardless of the CMMC certification level, defense contractors should have the following measures in place to safeguard sensitive product information throughout the entire lifecycle.
- Documented plans, policies, and procedures for addressing system security controls, incidence response, and risk mitigation
- System access controls to ensure that only authorized individuals (both internal and external) have access to sensitive product information
- Continuous monitoring for system vulnerabilities and assessment of security control effectiveness
- Cybersecurity awareness training for employees and external partners that reinforces the organization’s cybersecurity program. It should cover procedures on how to mitigate threats, handle sensitive product information, and respond to security breaches.
Because most of their efforts are focused on innovation, many aerospace and defense companies lack the resources, time, and budget to implement these extensive cybersecurity measures. Consequently, CMMC compliance may seem out of reach.
Arena PLM for AWS GovCloud Helps Support CMMC Compliance
As more defense contractors embrace modern technology like cloud-native product lifecycle management (PLM), they’re able to not only streamline product development but also bolster their compliance programs for export controls (ITAR/EAR) and cybersecurity regulations.
Today’s purpose-built PLM solutions with cloud-native architecture centralize all product information in a single digitized record. Secure web-based access enables globally dispersed teams to collaborate regularly on product development activities while minimizing security risks.
Arena’s Multilayered Security Aligns With FedRAMP Requirements
Where DoD contractors rely on external cloud service providers (CSPs) for covered defense information, DoD expects CSPs to be FedRAMP Moderate authorized or to meet DoD’s FedRAMP Moderate‑equivalency expectations, as clarified in DoD guidance. Arena by PTC has invested in implementation of the PTC Arena Federal Cloud Service Offering (CSO) aligned with the security requirements outlined in the December 21, 2023, Department of Defense memo entitled “Federal Risk and Authorization Management Program Moderate Equivalency for Cloud Service Provider’s Cloud Service Offerings.”
Arena’s multilayered security approach protects sensitive product information. Layers of protection include well-defined security processes and policies, firewalls, encryption of at-rest and in-transit data, user authentication, and continuous monitoring. Robust access management capabilities enable organizations to control the type of users and product information accessed. They also have a full audit trail of who accesses information and when they access it.
Arena PLM Security Model
This security model translates to significant savings of time and cost for businesses since they don’t have to establish a cybersecurity framework from scratch. Arena Federal is subject to regular independent third‑party assessments, which can help customers assemble evidence for relevant security controls. Customers remain responsible for their overall CMMC posture, including scope, policies/procedures, and implementation across people, processes, and technology.
Interested to learn more about Arena PLM for AWS GovCloud? Watch this demo.
References
Shelly St.Hill