CMMC New Year Compliance
January feels quiet. Fewer meetings. A lighter inbox. People easing back in.
But defense work does not wait for a clean start.
This is the week when primes ask for proof, contracting teams tighten requirements, and your next bid can hinge on one simple question:
Can you show your CMMC posture clearly, quickly, and in writing?
If your answer is “we’re close” or “our IT vendor said we’re covered,” New Year is when that gap turns into a scramble. The scramble usually looks like this:
Your team is chasing screenshots and policies
Someone realizes SPRS is missing a required post
Remote access is messy after holiday travel
A single outage or login issue slows work and pushes people into risky workarounds
And suddenly the “slow” week becomes the most expensive week of the quarter.
What “New Year compliance” actually means in CMMC terms
CMMC New Year compliance is not a slogan. It is your ability to start the year with:
A clear scope of what systems touch CUI and FCI
The right version of the standard applied the right way
Evidence that matches what an assessor or prime will ask for
Remote access that stays secure even when people are traveling
Resilience when a cloud provider, DNS, VPN, or identity service has a bad day
If you want a practical target, aim for this:
If someone asked you today for your CMMC Level 2 story, you could share it in one email thread without backtracking.
The most common New Year mistake: following the wrong “version”
A lot of teams hear “Rev 3 is here” and panic.
Here is the clarity that matters:
CMMC Level 2 is based on NIST SP 800-171 Revision 2 for assessment and scoring today.
NIST SP 800-171 Revision 3 exists and is final, but it is not what CMMC Level 2 is scored against right now.
So the smart move is not “switch everything to Rev 3 overnight.”
The smart move is:
Get clean on Rev 2 now, and build a controlled plan to absorb Rev 3 changes without blowing up your program.
NIST SP 800-171 Rev 3 was published as final on May 14, 2024.
The requirement that trips teams up: SPRS and award readiness
CMMC New year Compliance is where New Year gets real. Because even if your internal controls are improving, award workflows often depend on what is posted and affirmed.
In DoD’s DFARS ecosystem:
DFARS 252.204-7025 requires offerors to post the results of a CMMC Level 1 or Level 2 self assessment to SPRS prior to contract award, and identify the information systems that will process, store, or transmit FCI or CUI.
That is not a “later” task. That is a before-award reality in the flow DoD describes.
If you want one New Year action that reduces stress fast, do this first:
Confirm what is posted in SPRS, confirm it matches your scoped systems, and confirm the affirming official process is understood.
The hidden cost of “we’ll handle it later”
When teams postpone these checks, the damage usually shows up as:
Bid delays because someone cannot verify compliance status
Last minute policy writing that does not match the environment
Over-permissioned remote access because it is easier in the moment
Untracked tools used during downtime because people just need to work
Evidence gaps that create uncomfortable conversations with primes
It is rarely one big failure.
It is ten small gaps that collide when the year starts moving fast.
The New Year CMMC compliance reset
A practical 90 day path that does not overwhelm your team
Here is a clean way to run this without chaos.
1) Lock scope before you “fix” anything
Write down, in plain terms:
Which people, devices, and systems touch CUI
Which systems are in scope for CMMC Level 2
Where CUI lives, moves, and is shared
Which vendors and SaaS tools are part of that path
If scope is fuzzy, your controls and your evidence will be fuzzy too.
2) Make Rev 2 your audited baseline
Because CMMC Level 2 aligns to NIST SP 800-171 Rev 2 for scoring today, your January goal is:
A complete Rev 2 control map with owners
Evidence tied to each control
A living POA and M plan that is realistic, dated, and owned
This is how you avoid “paper compliance” that breaks under real questions.
3) Confirm SPRS readiness before bids heat up
Treat SPRS like a New Year gate, not a back-office chore.
Verify your posting status and documentation path for CMMC Level 1 or Level 2 self assessment results as described in DFARS workflows.
Also confirm your internal list of systems matches what you will identify in award workflows.
4) Harden remote access for the “travel month” reality
New Year includes travel, hybrid schedules, and “I’m logging in from somewhere else.”
Focus on:
Multi factor authentication everywhere it matters
Least privilege access that matches job roles
Device checks for managed vs unmanaged endpoints
Clear offboarding and access review routines
This is where a lot of “cheap IT” quietly creates long term risk.
5) Build cloud resilience so outages do not become security incidents
Outages happen. The goal is not perfection. The goal is continuity without risky improvisation.
Document:
Your backup path for DNS and critical services
Who flips what switch during an outage
What your team uses if VPN or identity is unstable
How you log and retain incident notes for audit trails
When the plan is clear, people do not panic click.
6) Start a calm Rev 3 transition plan
Rev 3 is real and it is worth preparing for.
But do it like adults:
Create a delta list between Rev 2 and Rev 3
Prioritize changes that improve security now anyway
Schedule updates around business cycles and contract priorities
Avoid rewrites that erase working evidence
You are not starting over. You are maturing.
A simple way to measure if you are ready
Ask yourself:
If a prime requested our CMMC Level 2 posture this week, could we respond in one business day with confidence?
If the answer is “maybe,” your New Year task is not more tools.
It is clarity, scope, evidence, and resilience.
Where Centrend fits
Centrend helps defense contractors start the year with a clean CMMC story that holds up in real life.
That includes:
Rev 2 aligned control mapping and evidence organization
Support for SPRS and award readiness workflows tied to DFARS expectations
Remote access hardening that does not slow the team down
Practical resilience planning so outages do not trigger risky workarounds
If you want an outside view, we can run a short CMMC New Year Compliance review and leave you with a prioritized 90 day action list your team can actually execute: Book a CMMC New Year Compliance review with Centrend