CMMC Holiday Cybersecurity Readiness. The holiday season is when your team slows down. Attackers see that as an open door.
Government alerts and real incidents show the pattern: ransomware and major cyber events often hit on holidays and weekends, when staff is thin and response is slower.
This year, that risk lines up with the CMMC final rule and new DFARS clauses showing up in real DoD awards. CMMC is now live in select contracts, and any gap can hit you twice: it hurts your eligibility and it increases the damage if an incident lands during a busy season.
So the question is simple: if a serious cyber event hit on a holiday, would your CMMC story hold up under real pressure?
This post gives you a clear way to test that before the next long weekend.
Why holidays are a stress test for your CMMC program
For most defense contractors, the holiday pattern looks like this:
- Fewer people watching alerts and tickets
- Change freezes on key systems
- More remote access from home networks, hotels, and family devices
- Vendors and partners on limited hours
Threat actors know this. CISA and other groups have warned that attacks during holidays and weekends are often slower to detect, take longer to contain, and cause more damage.
From a CMMC view, this hits the same control families you already have to meet:
- Access Control, Identification and Authentication
- Incident Response
- Audit and Accountability
- Contingency Planning and System Availability
These come straight from NIST SP 800-171, which CMMC Level 2 is built on.
A holiday incident is not only about stopping the attack. It is also about whether your controls still work when people are out and whether you can prove that to an assessor or contracting officer later.
The holiday risk that CMMC does not forgive
CMMC Holiday Cybersecurity Readiness. Now layer in where CMMC is today. The final rule and the DFARS “clause rule” are in effect, with a phased rollout into new contracts.
Key points that matter for the holidays:
- CMMC Level 2 ties straight to NIST SP 800-171 and expects working controls, not just paper.
- SPRS entries and affirmations must stay current, or your award eligibility can be at risk on new CMMC tagged contracts.
- If you are using Conditional CMMC status, you have only 180 days to close every POA&M item and confirm that closeout, or you can lose that status.
If that 180 day window runs through Thanksgiving, Christmas, New Year, and the usual vacation stretch, you cannot afford to “take a break” from your plan. The clock does not stop because your team is on holiday.
A holiday lens on your CMMC controls
Here is a simple way to look at your CMMC program through a holiday lens. Treat each section as a short talk with your IT, security, and contracts leads.
1. Who is watching when most people are out?
Link to controls: Incident Response, Audit and Accountability
Ask:
- Who is on call for security alerts during holidays and long weekends
- How fast can they reach someone who can isolate a system, disable an account, or pull logs
- Do they know where runbooks and incident response steps live, and are those easy to open from home
CISA and many surveys show that even a small delay in seeing and handling a holiday attack can multiply the damage.
Your holiday coverage plan should not live only in one person’s head.
2. Can people reach CUI systems safely from where they actually are?
Link to controls: Access Control, Identification and Authentication, System and Communications Protection
During holidays, people work from:
- Home offices that share Wi-Fi with game consoles and smart TVs
- Family houses or travel rentals
- Airports and hotels
Check:
- Are MFA and strong authentication in place for all CUI systems
- Is remote access through a hardened method (such as a secured VPN or zero trust access), not ad hoc tools
- Are there clear rules about using personal devices with CUI, and are those realistic for how people work when they travel
CMMC Level 2 expects you to manage who connects, from where, and how traffic is protected.
If your rules are strict on paper but ignored during busy periods, that gap will show.
3. If ransomware hit on a holiday, how would recovery really go?
Link to controls: Contingency Planning, System and Information Integrity, Media Protection
Ransomware during a holiday is one of the scariest cases. Government advisories highlight that many organizations take longer to respond and recover if the incident starts when key staff is away.
Ask:
- When was the last time you tested a restore of key CUI systems from backup
- Are there offline or immutable backups that ransomware cannot easily reach
- If you had to rebuild a core system over a holiday weekend, who would be involved and how would you reach them
CMMC and NIST 800-171 both expect working backup and recovery, not just a line in a plan.
4. Does your conditional status or POA&M plan survive the holiday calendar?
If you are relying on Conditional CMMC Status for Level 2 or 3, your holiday planning is not just about risk. It is also about deadlines.
By rule, conditional status:
- Is allowed only for Level 2 and 3
- Must be backed by a POA&M listing open gaps
- Expires after 180 days if you do not close those items and complete a closeout assessment
After that, you risk losing that status.
Holiday view:
- Do any of your key POA&M tasks fall in periods when your main staff or vendors are out
- Are there high friction tasks (for example, firewall redesigns, identity changes, or major system upgrades) that should not be left to late December
- Does leadership understand that the 180 day timer is a hard limit, not a “nice to have”
If the calendar looks tight, move work earlier in the season, not later.
5. Will your logs and evidence tell a clear story after the holidays?
A holiday incident often becomes a test case. Assessors, primes, or the government may ask what happened, how you responded, and how your plan lined up with your policies and SSP.
Tie this back to:
- System Security Plan (SSP)
- Incident response playbooks
- Audit logs and monitoring
- Change records and POA&M updates
Good questions:
- Are logs for CUI systems stored long enough to cover the full holiday season and past incidents
- Are incident tickets and notes captured in a place you can show in a future CMMC assessment
- Do your diagrams and SSP reflect the way people really connect during holidays, including VPNs, cloud services, and remote devices
NIST 800-171 and CMMC Level 2 expect not only technical controls but also documentation and traceability.
A short holiday CMMC readiness plan
You do not need a huge project before the next break. Even a focused plan over a few weeks helps a lot in CMMC Holiday Cybersecurity Readiness.
1st Week Review and map
- List key CUI systems and services your team will use over the holidays
- Note which are covered by Level 2 or 3, and whether status is Conditional or Final
- Pull your latest SSP, incident response plan, and POA&Ms that fall in the next 60–90 days
2nd Week Fix fast gaps
- Confirm holiday on call coverage for security alerts and incidents
- Check MFA, VPN, and remote access settings for CUI systems
- Test a small restore from backup for at least one critical system
3rd Week Align evidence and status
- Make sure monitoring and logging for CUI systems is working and stored where you can use it later
- Update POA&Ms and schedules to avoid tight deadlines in peak holiday weeks
- Check that your SPRS status and affirmations match the current environment and level
4th Week Run a small holiday drill
- Simulate a simple incident for a CUI system on a holiday or weekend scenario
- Time how long it takes to notice, respond, and start recovery
- Capture the steps, screenshots, and logs and attach them to your CMMC evidence set
By the end of this short plan, you have something powerful:
You can show that your CMMC program still works when staff is thin, when people are remote, and when attackers are most likely to try their luck.
Turning holiday risk into a strength in your CMMC story
CMMC Holiday Cybersecurity Readiness is not only about passing an audit. It is about showing that your team can protect FCI and CUI in real conditions, including during the busy, distracted, and under staffed weeks of the year.
Holiday cyber events are a harsh test. They stress:
- Your people and coverage
- Your access control and remote work setup
- Your backup and recovery
- Your documentation and POA&M discipline
Defense contractors that will feel confident in the next wave of CMMC contracts will be able to say:
- “We did not treat holidays as blind spots in our risk plan.”
- “Our CMMC controls, runbooks, and POA&M work even when the office is quiet.”
- “We have real logs and examples that show how we handled peak season risk.”
How Centrend can help your team before the next holiday
If you want help turning these ideas into action, Centrend can:
- Review your CUI systems and CMMC level in a holiday risk lens
- Check your Conditional vs Final status, POA&M timelines, and holiday overlaps
- Design a simple, repeatable Holiday CMMC Readiness Review that you can reuse every year
A short working session now can save you from a long and painful incident later, and it gives you stronger evidence for your next CMMC assessment and DoD bid.