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11/07/2026 1:56 pm
TL;DR: CMMC 2.0 readiness now affects contract eligibility, SPRS scores, flowdown obligations, and False Claims Act exposure, according to Exostar, which argues that IT-only programs fail because legal, contracts, compliance, and security decisions have to align. The governance problem is no longer technical capability alone, but evidence, accountability, and scope control across the full lifecycle.
NHIMG editorial — based on content published by Exostar: Why CMMC Readiness Is No Longer Just an IT Project
By the numbers:
- 72% of organisations have experienced or suspect they have experienced a breach of non-human identities.
- Enterprises that have experienced a compromised NHI averaged 2.7 separate incidents in the past 12 months.
Questions worth separating out
Q: What breaks when CMMC readiness is treated as an IT-only project?
A: It breaks the link between technical controls and the contractual obligations they are meant to satisfy.
Q: Why does CMMC create accountability risk beyond cybersecurity compliance?
A: Because the programme sits inside contract law, not just security policy.
Q: How should teams govern identity and access evidence for CMMC?
A: Teams should connect IAM, PAM, and review records to the exact requirement they prove, then maintain that evidence through the contract lifecycle.
Practitioner guidance
- Define CUI scope with legal and contracting input Map each contract clause to the systems, users, and third parties that actually process CUI before building the control plan.
- Link identity evidence to contractual obligations Make access approvals, privileged reviews, and exception records traceable to the specific contractual requirement they support.
- Validate SPRS and assessment artefacts before submission Review scores, affirmations, and supporting evidence against actual implementation status so that documented posture matches operational reality.
What's in the full article
Exostar's full article covers the operational detail this post intentionally leaves for the source:
- How the vendor maps DFARS clauses to specific compliance responsibilities across legal, contracts, compliance, and IT.
- Why inaccurate SPRS submissions can create contractual and legal consequences beyond a failed assessment.
- How organisations should think about CUI scoping when third parties, remote access, or subcontractor flows are involved.
- What sustained readiness looks like across annual affirmations, reassessments, and contract performance.
👉 Read Exostar’s analysis of why CMMC readiness is now a legal and business risk issue →
CMMC readiness and the governance gap teams are missing?
Explore further
11/07/2026 2:07 pm
CMMC readiness has become a governance problem before it is a tooling problem. The article is right to move the centre of gravity away from IT-only execution. When contract eligibility and performance depend on evidence, organisations need coordinated control ownership across legal, contracts, compliance, and security. That is especially true where identity and access determine who can touch CUI or approve exceptions. Practitioners should treat readiness as an enterprise control system, not a technical project.
A question worth separating out:
Q: Who should own CMMC readiness when multiple teams are involved?
A: Legal, contracts, compliance, IT, and security all need defined ownership because each controls a different part of the obligation. The programme fails when any one function assumes another team is handling scope, interpretation, or evidence. A cross-functional model is the only way to keep contractual commitments aligned with control operation.
👉 Read our full editorial: CMMC readiness is now a legal and identity governance issue
