If your organization does business with the federal government fulfilling contracts under the purview of the Department of Defense — or works as a subcontractor to someone who does — change is here. A small but powerful update to Title 48 of the Federal Acquisition Regulation System (FARS) went into effect on September 10th, and it will directly impact manufacturers in the months ahead.
What is Title 48?
Title 48 governs the Federal Acquisition Regulation System, the framework every federal agency follows when buying products or services. Think of it as the rulebook that drives how terms and conditions (Ts & Cs) are written into federal contracts. Specifically, the update to FARS published on September 10th prescribes contract language for contracts under the purview of the Department of Defense (DFARS).
Why does this matter? Because if an agency fails to include the right cybersecurity language—or adds something they shouldn’t—they could be held accountable. That makes Title 48 the enforcement mechanism behind cybersecurity requirements like the Cybersecurity Maturity Model Certification (CMMC).
Title 32 vs. Title 48
- Title 32: Defines the CMMC program itself—what the requirements are and how compliance is measured.
- Title 48: Enforces those requirements by ensuring they appear in contracts.
For years, organizations have known CMMC was coming. With the new Title 48 language finalized, the countdown is over. Starting November 10, 2025, contracting officers will begin phasing CMMC clauses into new and existing DoD solicitations and contracts.
Why Manufacturers Must Act Now
If you manufacture for the defense supply chain, you will soon see new cybersecurity clauses in your contracts. Depending on your role:
- Prime contractors will often need to achieve CMMC Level 2 certification, with Level 3 reserved for a small set of the most sensitive national security contracts.
- Subcontractors may fall under Level 1 (annual self-assessment) or Level 2 (self- or third-party assessment, depending on contract and how your organization handles FCI or CUI data). It is the responsibility of the Prime Contractor to ensure its subcontractors are assessed at the correct level. As such, subcontractors are strongly advised to seek guidance from their Prime regarding the CMMC level to which they will be held and should be assessed.
Organizations must provide an annual affirmation of compliance and undergo full recertification every three years at the level required by their contracts.
This isn’t just a box to check—it can take 6–12 months to close security gaps and pass an assessment. Waiting any longer could put existing contracts, renewals, and future awards at risk.
Who Oversees CMMC?
- CyberAB – The governing body that manages the entire CMMC ecosystem.
- C3PAOs – Certified Third-Party Assessing Organizations who perform the audits.
- RPOs (Registered Practitioner Organizations) – Experts trained and recognized by the CyberAB to help companies prepare.
Our team includes Registered Practitioners (RPs and RPAs) who are trained and well-versed in both Title 32 and Title 48. That means we understand not just what CMMC requires, but how to implement it in your environment so you’re ready when it shows up in your contract.
How We Can Help You Stay Ahead
We don’t just explain the rules—we help you win business by staying compliant. Our proven approach includes:
- CMMC Gap Analysis – Identify where you stand today.
- Remediation Roadmap – Build the plan to close gaps quickly and effectively.
- Implementation Support – Hands-on help deploying the right controls and processes.
- Ongoing Oversight – Through our vCISO service, we provide the vision and leadership of a cybersecurity executive for a fraction of the cost.
For many manufacturers, vCISO is the smartest path forward. A 12-month engagement gives you the runway to prepare properly, stay on track, and demonstrate compliance when contracts demand it. Plus, it ensures your subcontractors stay aligned—helping you avoid costly disruptions in the supply chain.
Next Steps for Manufacturers
- Find out your required CMMC level (Prime vs. Sub).
- Schedule a gap assessment to understand where you stand today.
- Engage a partner you can trust—we’re recognized by the CyberAB, experienced with manufacturers, and ready to help you get compliant.
Bottom line: Title 48 means CMMC is no longer “coming soon.” It’s here and will be written into contracts starting November 10, 2025. Manufacturers who act now will protect revenue streams, strengthen their security posture, and gain a lasting competitive advantage.
👉 Leverage the expertise of our CTO, Vin DiPippo, RP and Steve Doman, Cyber Security Program Manager, CISO, RPA and contact us now to schedule your CMMC readiness assessment to lock in your vCISO Advantage engagement.
