Topic starter
11/07/2026 8:41 pm
TL;DR: CMMC waivers are rare, time-bound exceptions that apply only at the procurement level, and the DoD says they do not remove underlying cybersecurity obligations, according to Secureframe’s analysis of the January 2025 memo and 32 CFR rule. Delaying certification in hopes of a waiver leaves contractors exposed to lost awards, flowdown pressure, and avoidable contract risk.
Editorial analysis by NHI Mgmt Group, based on content published by Secureframe: “The Myth of CMMC Waivers: 7 Misconceptions that Are Putting Your Contracts and Information at Risk”.
Key questions
Q: What happens when a defence contractor assumes CMMC will be waived?
A: The contractor can end up chasing an exception that does not exist, while still carrying the underlying cybersecurity obligations tied to the work.
Q: Why do CMMC waivers not remove the underlying security burden?
A: Because the waiver changes assessment requirements, not the need to protect controlled information.
Q: What fails when defence contractors plan around CMMC waivers instead of certification?
A: The failure mode is governance drift.
Practitioner guidance
- Treat waiver assumptions as procurement risk Inventory every active and pending defence contract for waiver assumptions, then verify whether the contract actually allows a waiver path or still requires certification evidence before award.
- Align subcontractor flowdown with CMMC readiness Require supplier status checks, assessment evidence, and contractual flowdown review before a prime can rely on downstream delivery commitments.
- Separate exception handling from baseline readiness Build a clear decision path for mission-critical exceptions so leadership cannot confuse a time-bound procurement waiver with organisation-wide compliance readiness.
Bottom line: CMMC waivers are narrow procurement exceptions, not a general alternative to certification for defence contractors.
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11/07/2026 9:10 pm
Waiver chasing is a governance anti-pattern, not a compliance strategy. The article shows that defence contractors cannot use procurement exceptions as a substitute for provable control operation. Once a programme depends on a waiver to preserve business continuity, the organisation has already accepted a weaker security posture than the contract environment demands. Practitioners should read this as a warning that certification readiness must be treated as a condition of market access, not a discretionary control objective.
A question worth separating out:
Q: Should organisations prioritise CMMC certification before relying on contract exceptions?
A: Yes. Certification readiness is the durable path to repeatable access to defence work, while waivers are rare, time-bound, and tied to specific procurement conditions. Organisations should plan around control evidence, assessment timing, and subcontractor flowdown instead of building a business case on exceptions.
👉 Read our full editorial: CMMC waivers are a myth for most defense contractors