CMMC Readiness Can't Be Bought, Paused, or Rushed

The CMMC pause changed one thing, and it wasn't the requirement. Cybersecurity consultant Brandi Narvaez explains why readiness only holds when it is built into daily operations, and why tools, pauses, and shortcuts keep failing the contractors who lean on them.

Most defense contractors are not ignoring CMMC. They are working on it, often hard, in a landscape that keeps moving under their feet.

The problem is what they are leaning on to get there. A new product that promises to close the gap. A pause that seems to buy time. A plan to compress the work once the pressure returns.

Brandi Narvaez has spent about 25 years in cybersecurity, long before most people called it that, and works independently guiding clients through their security and compliance projects. On BEMO's Security + Compliance Field Guide, she made a case that cuts through all three shortcuts.

This article is for owners and executives at small defense contractors who carry the contract risk, and for the IT and operations leads doing the work. If readiness feels like something to buy, wait out, or rush later, this is why it does not work that way.

Contractors are trying. The ground keeps shifting.

Brandi's read on the state of readiness starts generously.

"People are trying. It's a very large landscape, and unfortunately, it is changing at this point by the minute. With the influx of AI and everything that's happening, cybersecurity changes by the minute, and organizations have to be nimble and adapt."

She is equally candid about the limits. It is almost impossible to plug every hole in the dam, so organizations have to focus on what matters most to their operations while still understanding what they are being protected against.

And for most of the contractors she works with, the immediate driver is regulatory. They need to meet the requirements that govern them to stay engaged and stay in business. Most also genuinely want their data, assets, employees, and customers protected.

That combination, real effort plus real pressure, is exactly what makes shortcuts tempting.

Readiness can't be bought

The first shortcut is the purchase. Brandi is blunt about where it goes wrong.

"Choosing a vendor to help them that is fitting a square peg in a round hole. People get wrapped around a bright, shiny new product, the silver bullet of the week, and it doesn't actually solve the problems."

Her test is simple. Does the purchase remediate a real risk, and what business value does it drive? If a vendor is selling toward its own product rather than your problem, the tool becomes activity instead of progress.

The deeper reason no product closes the gap is where the risk actually lives. For Brandi, whose core work for two decades has been identity governance, it lives with people.

"You can control a network switch. You can control a firewall. You can control an EDR package on an endpoint. You can't control a user."

That is why she points to identity governance as the single most critical capability: who has access, what access they have, and how it is managed across its full life cycle. A tool can enforce a policy. Someone still has to define, operate, and own it.

AI makes this harder, not easier.

"How are you creating and managing AI bots and things that are working on behalf of your users? That's an extension of their identity, and I think people have yet to even wrap their head around that and the risk that it creates."

She sees the same gap in everyday access. People expect data at their fingertips on personal phones and laptops because that is how their personal lives work. Her position is not ease of access but control: regulated, multi-factor, the right person accessing the right thing at the right time.

Readiness can't be paused

The second shortcut is the pause. When the CMMC Phase 2 pause was announced in July, it was easy to read it as everything stopping. Brandi breaks down why that read is wrong.

"There are three parts to CMMC. There is the requirement of it, the verification of it, and then the enforcement of it. And the only thing that paused actually was the verification."

The requirement is still in contracts today. Enforcement is still there too, including the government's ability to act under the False Claims Act if something happens. Only the middle piece, a C3PAO completing an assessment and certifying the organization, moved.

She was working with a client when the announcement landed. Their C3PAO assessment was scheduled for the first week of August, and they asked whether to stop.

"I said, 100% do not stop. We've been working towards this. It is still a requirement. Keep moving."

Her reasoning goes beyond the regulator. The work required to meet the 110 NIST requirements protects the organization itself, so there is inherent safety in completing it whether or not anyone is verifying it this quarter.

She also expects verification to return in some form. In her view, self-assessment will likely evolve rather than disappear, and the work does not get lighter.

"The burden of the requirement doesn't change, it's just how you achieve it."

Not sure what the pause changed for your contracts? BEMO can walk you through what is still required, what moved, and where your program stands today.

Readiness can't be rushed

The third shortcut is the plan to catch up later. This is where Brandi's analogy does the most work.

"It takes one woman nine months pregnant to have a baby. You can't have nine women one month pregnant and still have a baby."

Readiness involves layered changes: procurement with other vendors, changes to the technology stack, and a long chain of decisions made along the way. Each depends on the one before it.

In her words, getting those done in the natural flow of a timeline cannot be compressed. That is what makes stopping so costly.

"Keep going, finish your work. Don't get behind on this because you won't be able to catch up."

Adding more people or more budget later does not shorten the sequence. Contractors who pause now are not saving time. They are deferring work that will take just as long when they restart, under more pressure.

A better standard: can your leadership sleep at night?

If readiness can't be bought, paused, or rushed, what should contractors aim for instead? Brandi's answer replaces the checklist with a much more honest test.

"The real goal is can your CISO, can your CIO, can your CEO sleep at night?"

That looks different for every organization, depending on its assets, users, and industry. But it has a practical edge. Leadership should be able to answer questions from their cyber insurance provider honestly and accurately.

It also accepts that some risk will always remain. The point is to acknowledge it, manage it, and choose deliberately what to leave on the table in the best interest of the business.

This is where compliance chasing and real maturity split. Compliance chasing is built around the next assessment. Maturity is built into how the business runs.

"It's not about meeting a framework once every three years. It's about living it every day. Your organization needs to be living it, that's what I think people miss."

She does not pretend this is easy. Living it requires significant change, a lot of adoption, a lot of work, and a lot of monitoring. But it is the only version of readiness that survives a pause, a framework change, or a new wave of AI risk.

What this asks of the people running the program

Brandi's argument lines up with how BEMO approaches security and compliance: build real security into daily operations, and the certification follows as a byproduct.

In practice, living it every day means three things.

Someone has to own the outcome, not just the tools. Platforms and products monitor and enforce. Implementation, evidence, and auditor coordination are the work. BEMO takes responsibility for that full path to CMMC Level 2, from configuring security in Microsoft 365 to coordinating the C3PAO assessment and operating the environment afterward.

Identity and access have to be governed continuously. Brandi's top risk, who has access to what and how it is managed over time, is not a one-time setup. It is an operational discipline that has to keep pace with new users, new devices, and new AI agents acting on their behalf.

The work has to keep moving. The requirement did not pause, and the timeline cannot compress. A partner that runs the program alongside your team keeps progress steady regardless of what happens to verification schedules.

BEMO has been through this itself. It earned its own CMMC Level 2 certification, so the operational habits it builds for clients are the same ones it lives with.

The takeaway

CMMC readiness is not a product, a deadline, or a sprint. The requirement is still in your contracts, enforcement is still in place, and the work still takes the time it takes.

The contractors who come out ahead will be the ones who kept going, governed who has access to what, and built compliance into how they operate every day, so leadership can sleep at night no matter what changes next.

 Keep your CMMC program moving. Talk to BEMO about where your readiness stands today and what it takes to live it every day.