110 Security Controls by 2026, or You're Out

By fiscal year 2026, every new DoD contract requires CMMC Level 2 certification. That's all 110 security controls from NIST SP 800-171 Rev 2

Government Report:NIST✓

. Access control, encryption, audit logs, incident response, employee training, physical security—all of it. A 2024 Merrill Research study found that only 4% of defense contractors were fully prepared for CMMC certification

Industry Study:CyberSheath✓

. The same study reported that 41% had completed self-assessment requirements, with an average SPRS score of -12

News Article:GT Law✓

. Implementation costs run $63,000–$200,000 per site depending on organization size

Source:Paramify✓

. No certification means no bidding on new contracts. Not "maybe." No.

Here's the Timeline

CMMC Enforcement Timeline

1

2023

Proposed rule published

2

2024

Final rule effective December 16, 2024

3

2025

DoD starts inserting clauses into RFPs

4

2026

All new contracts require valid CMMC Level 2 certification

Self-assessment doesn't cut it anymore. Level 2 requires third-party audit by a C3PAO (authorized assessor). They check all 110 controls. If you're not compliant, you're disqualified from bidding.

What's Actually Required

NIST SP 800-171 Rev 2 defines 110 security controls for protecting CUI

Government Report:NIST✓

. The DoD estimates that out of approximately 300,000 defense contractors, about 80,000 will require Level 2 certification

Source:Summit7✓

Industry Study:MxD USA✓

. These controls cover:

• Access Control: Role-based, system-level access to CUI
• Audit and Accountability: Traceability of who accessed what, when
• Configuration Management: Protection against tampering
• Identification and Authentication: Multi-factor authentication, unique user IDs
• System and Information Integrity: Error detection and correction
• Media Protection: Protection of digital engineering data
• Incident Response: Documented procedures for breaches
• Maintenance: Secure updates and patching
• Physical Protection: Secured facilities for IT systems
• Personnel Security: Background checks and training
• Risk Assessment: Regular security evaluations
• Security Assessment: Ongoing monitoring
• System and Communications Protection: Encryption and secure transmission

Many aerospace MROs are still in early stages. Common gaps:

• Limited IT support
• Incomplete logging
• Ad hoc access control
• No audit trail tied to engineering activity

Without Level 2, you're barred from new DoD contracts starting 2026. For aerospace MROs servicing military aircraft or defense systems, CMMC compliance is as critical as quality compliance. Just as a lapse in quality can lose AS9100 certification, a lapse in cybersecurity loses you contracts—or leads to breaches that shut down operations.

How MLNavigator Covers Key Controls

MLNavigator provides:

• Fully offline appliance (Mac Studio or secure cluster)
• Role-based access controls on engineering documents
• Immutable audit logs of drawing reviews and changes
• AI-driven compliance scanning during design review
• All data on-premises—no external exposure
• Compliance reports for CMMC auditors

By integrating quality management with cybersecurity hygiene, your journey toward CMMC Level 2 compliance accelerates as a byproduct of improving your processes.

What This Costs

Without CMMC Level 2, aerospace MROs risk losing access to federal contracting opportunities valued in the hundreds of billions annually

Government Report:DoD CIO✓

. Implementation typically runs $63,000–$200,000 per site depending on scope

Source:Paramify✓

. Most of that goes to consultants piecing together disparate systems. MLNavigator deployments start at $10k–$75k depending on scale—a fraction of typical compliance consulting bundles. You get an appliance designed from the start to support CMMC requirements, not a retrofitted patchwork. For investors: CMMC Level 2 compliance isn't just a checkbox—it's a revenue prerequisite. With enforcement beginning 2026, suppliers unable to certify get disqualified from new DoD work. That creates a tailwind for solutions that accelerate compliance. Once a shop deploys MLNavigator and builds learned standards into the system, switching costs become high. Audit history, adapter training, process integration—all locked in.

Timeline Note

CMMC implementation will phase in through 2028, with early enforcement beginning November 10, 2025 for certain contract types.

Gauge Your Readiness

To assess your organization's CMMC Level 2 readiness, conduct a comprehensive gap analysis against the 110 NIST SP 800-171 controls. Focus on access control, audit logging, system integrity, and configuration management as these areas often require the most significant implementation effort.

What to Do Next

The clock is ticking toward 2026. Waiting until the last minute means competing for limited C3PAO assessment slots and paying premium prices for rush implementations. Talk to us about deploying MLNavigator for your first site. Get a readiness evaluation in under 48 hours. Protect your eligibility—before enforcement closes the door. Tens of thousands of suppliers must comply by 2026-2028. Solutions that streamline compliance will be in high demand. MLNavigator tackles the data and documentation aspects through automation—helping mid-sized aerospace firms get CMMC Level 2 faster and with less pain. Note: MLNavigator supports your compliance program; CMMC certification remains the responsibility of your organization.