General contractors can no longer bid on DoD jobs without CMMC compliance. That’s a big opportunity.
- Construction firms and other vendors that do business with the DoD can no longer bid on new contracts unless they meet CMMC 2.0 cybersecurity standards.
- Achieving compliance will give your firm access to opportunities that many of your competitors won’t qualify for; however, compliance is too complex to tackle on your own.
- Work with a registered provider organization (RPO) to assess your current compliant gaps and implement improvements, while maintaining a focus on how compliance can align with your operational and jobsite needs.
Contractors and other vendors who work with the Department of Defense must now meet the Cybersecurity Maturity Model Certification (CMMC) 2.0 standards to be eligible to bid on new DoD contracts. CMMC 2.0, which is a cybersecurity framework aimed at protecting controlled unclassified information (CUI), kicked off a three-year, four-phase rollout after the final rule took effect on November 10, 2025.
The rule requires compliance with specific, tiered cybersecurity standards (self-assessments or third-party certifications) to be listed in the Supplier Performance Risk System (SPRS) — and meeting those standards is a complicated process. However, because many construction firms may forgo DoD bids rather than become CMMC compliant, companies that do achieve compliance will face limited competition for contracts.
Keep reading to learn more about how CMMC works and how to make your compliance journey simpler and more effective.
CMMC 2.0 cybersecurity compliance is mandatory for all new DoD contracts
All new DoD contracts contain a clause requiring the vendor to certify compliance with CMMC 2.0 cybersecurity rules. However, because CMMC is taking effect in phases, the specific requirements you’ll need to meet will evolve over time:
- During the first implementation phase, which lasts through November 9, 2026, you can certify compliance by doing a self-assessment and attesting that your business meets CMMC standards.
- During the next three phases of the CMMC rollout, which kick in at one-year intervals beginning November 10, 2026, you will also be required to complete an external CMMC assessment conducted by a certified third-party assessor organization (C3PAO) to bid on many jobs.
- CMMC compliance is typically assessed at the time of contract award, not when work actually begins, which means there is real urgency here for contractors, as achieving compliance doesn’t happen overnight.
- You should also note that contractors are also responsible for ensuring that any subcontractors they share CUI with also meet CMMC standards.
There’s also a major risk management element to consider here. At any point, you can be audited on your compliance — and if you don’t meet CMMC standards, you may be subject to substantial fines under the False Claims Act.
CMMC-compliant contractors now face less competition for DoD jobs
Many contractors are opting to forgo DoD bids, at least for now, rather than take the steps to become CMMC compliant. This makes DoD contracts less competitive than in years past, which means that construction firms that make the upfront investment in compliance now will have an easier time winning DoD bids.
In other words, there’s actually a huge opportunity here for firms willing to adjust. And it’s likely one that will only continue to grow, as more federal agencies will likely roll out similar cybersecurity requirements in the coming years.
Contractors that make the leap now will have a head start on their competitors and the potential to grow their federal contracting business while slower-moving peers are still just trying to understand this new regulatory environment.
How can your construction firm achieve CMMC certification?
Don’t try to tackle CMMC certification on your own. The rules are too dense and intricate for non-experts to implement — to the point that you risk failing a DoD audit because you don’t realize that your good-faith internal compliance effort doesn’t even come close to meeting standards. Instead, work with a registered provider organization (RPO) to bring your business into compliance.
What is an RPO?
An RPO is an advisory firm that specializes in helping companies meet CMMC compliance standards. An RPO can help you prepare to complete both a Phase 1 self-assessment and the third-party external assessment required for many jobs starting in Phase 2.
What does an RPO actually do?
An RPO will assess your current cybersecurity capabilities, identify gaps, and make recommendations for areas that need improvement. Advisors from your RPO will also work with your team to actually implement changes needed to bring your business into CMMC 2.0 compliance.
How do you choose the right RPO?
Do your due diligence when choosing an RPO. An RPO that understands CMMC compliance but doesn’t know the construction business can harm your firm by implementing compliance in a way that significantly interferes with your work. Look for an RPO with deep experience in federal regulatory compliance, cybersecurity and construction.
What are the major challenges for construction firms when implementing CMMC?
CMMC rules apply to all DoD vendors and supply chain companies, not just construction firms. But contractors face additional challenges when implementing CMMC, including not just change management and culture shock, but practical questions about how you can maintain compliance while sharing CUI among contractors, subcontractors and workers in the field.
The right RPO can help you navigate these waters, including key challenges like:
Maintaining subcontractor compliance
General contractors who attest to their own compliance are also responsible for any subcontractors they use. This can quickly get complicated, as sensitive data may be shared with dozens or even hundreds of workers on a job site or involved in planning efforts.
Do your due diligence and ask your subcontractors about their own compliance efforts to understand where they are in this process. You can also explore creating an enclave to protect CUI and other sensitive information, essentially allowing subcontractors to log into your systems via a portal rather than simply sharing files, which can help limit the spread of data.
Avoiding workflow interference
The best compliance program in the world is useless if it prevents your business from operating effectively. Equally useless is a compliance effort that interferes with your workflows to the point where your team just ignores it.
In other words, it’s not enough to be compliant; you have to do it in a way that fits with the realities of the job. That’s why it’s critical to tackle compliance with an eye towards your specific processes, culture and operations and design an approach that fits within that framework.
Overcoming culture shock
Construction has long been one of the most lightly regulated sectors of the economy, which makes strict CMMC requirements a genuine culture shock. You’ll need to change significant aspects of how you work, including transitioning away from paper and into digital tools and incorporating new security standards into your day-to-day activities.
And because compliance isn’t a one-and-done effort, you’ll need to sustain an ongoing culture of compliance. This takes time to implement and demands buy-in from leaders who may be used to doing things a certain way.
Managing change
Compliance is also an exercise in change management. Before you jump into a compliance effort, be honest about how much change your business is prepared to handle. You’ll need to make a lot of changes, fast, to become compliant — is your team up for that?
It’s essential to have an open dialogue within your company about the compliance process. This includes your job-site workers, who will have to follow through with compliance efforts while actively doing construction in the field.
CMMC may be about cybersecurity, but compliance is not just an IT issue, so the more you can involve your whole team in a collaborative effort here, the better.
What are your next steps to achieving CMMC compliance?
If you want to bid on new DoD contracts or prepare for future cybersecurity requirements by other federal agencies, here’s how to start your CMMC 2.0 compliance process:
- Find an RPO: Conduct a search for an RPO that specializes in CMMC compliance specifically for construction firms and understands the nuances of your business.
- Do a gaps assessment: Ask your RPO to assess your current cybersecurity practices and identify areas of improvement needed to meet CMMC standards.
- Create a CMMC roadmap: Based on your gaps assessment, work with your RPO to create a CMMC roadmap to outline specific steps you’ll need to take to achieve compliance, with a focus on how you can keep your efforts aligned with operational and jobsite requirements.
- Implement your CMMC roadmap: Make the specific changes outlined in your compliance roadmap, while maintaining ongoing communication with your team to ensure a smoother change process.
- Complete a self-assessment or third-party assessment: Depending on when you undertake this compliance process and the type of job you’re bidding on, you’ll complete either a compliance self-assessment or third-party assessment. At this point, you’ll be able to take on new DoD jobs.
How Wipfli can help
We help construction firms improve performance, navigate change and grow. As a registered provider organization (RPO), we also guide you into CMMC compliance. Let’s talk about your goals.
Let’s make your construction business stronger