Written By Gerson Pacheco
“A chain is only as strong as its weakest link” — a timeless proverb that rings especially true in the race for CMMC compliance, where your supply chain’s hidden vulnerabilities, particularly non-compliant subcontractors, can become the weakest link in your cybersecurity defenses.
If you’re a contractor working in the DIB, you’re likely focused on achieving CMMC compliance. Are your policies documented? Is your System Security Plan (SSP) up to date? Are you gathering evidence for an assessment? These are critical steps everyone needs to take, but the bigger piece many overlook is their supply chain. Specifically, your subcontractors.
I’ve seen this issue surface many times in client conversations. A company, who’s pouring resources and hours to achieve their level of CMMC compliance, only to discover their subcontractors, often small businesses with limited resources, are far from compliance.
CMMC 2.0, the DoDs framework for protecting CUI and FCI, requires all contractors and subcontractors handling sensitive data to meet specific cybersecurity standards. I recently had a conversation with a client who informed me that their prime contractor was already informing them of the requirement to be CMMC Lvl 2 compliant or risk losing their contract. Not in 2026, but now. This is the new reality.
What you need to do now
So, how do you protect your business? Start with awareness. Do you know where your subcontractors stand on CMMC compliance? Many assume their partners “probably” have it covered, but assumptions are risky. Make a list of your key suppliers and ask about their readiness plans. A simple email can spark critical conversations.
Next, prioritize communication. If you’re a subcontractor, don’t wait for your prime to ask about your status—be proactive. Share your CMMC roadmap to build trust. If you’re a prime, don’t let a critical supplier become a bottleneck. Open dialogue now gives everyone time to prepare, avoiding last-minute scrambles.
Finally, embrace collaboration. Some primes are helping their subs by recommending cybersecurity solutions, or connecting them with trusted CMMC consultants. Subcontractors can take initiative, too, by showing primes their progress: “Here’s our plan, here’s our timeline.” This transparency strengthens the entire supply chain.
Don’t wait, because the train has already left the station. Time is critical with CMMC. Achieving compliance, updating policies, implementing controls, gathering evidence, and preparing for assessments all takes months, not weeks. Subcontractors, especially small businesses, may struggle with the complexity, but the alternative is worse. A single breach can cost millions, far outweighing the investment in compliance.
Think of CMMC like building a secure compound. Your internal systems, policies, controls, evidence, are your walls and gates. But your supply chain? That’s the perimeter. If your subcontractors’ defenses are weak, the whole compound is at risk. You can’t control everything your suppliers do, but you can control whether you’re asking the right questions and planning ahead.
If you’re feeling overwhelmed, you’re not alone. Many contractors are still navigating CMMC, let alone their supply chain. Start small: list your key subcontractors, reach out, and ask about their CMMC plans. That first step could save you from a costly blind spot.