The Countdown to 2026 – Meeting 110 CMMC Level 2 Security Practices
Executive Summary
By 2026, defense suppliers must pass a CMMC Level 2 audit to bid on contracts. This includes implementing all 110 security controls from NIST SP 800-171, covering everything from access control and encryption to audit logs and incident response. Yet fewer than 5% of suppliers are actually ready. MLNavigator accelerates readiness by offering a pre-hardened, air-gapped AI appliance that embeds data governance and access control into the heart of your engineering workflow — no consultants, no cloud required.
Sources: https://dodcio.defense.gov/cmmc/About/, https://www.nationaldefensemagazine.org/articles/2024/10/1/few-companies-ready-for-cmmc-compliance-study-finds
Timeline to Enforcement
CMMC Enforcement Timeline (2023–2026)
Cybersecurity has become a non-negotiable part of doing business with the U.S. Department of Defense. The new Cybersecurity Maturity Model Certification (CMMC) 2.0 program requires defense contractors to implement a comprehensive set of controls to protect sensitive information.
For most suppliers that handle Controlled Unclassified Information (CUI), this means achieving CMMC Level 2 compliance – which involves meeting all 110 security practices outlined in NIST SP 800-171. The Pentagon is phasing in these requirements now, with the expectation that by fiscal year 2026, all new defense contracts will require CMMC certification.
Reality for Defense Contractors
Fewer than 4% of the 80,000+ suppliers in the Defense Industrial Base (DIB) are ready for Level 2
Certification costs average $105,000–$118,000, per entity
Lack of compliance disqualifies suppliers from contract awards
- Only certificates from C3PAOs (authorized auditors) are accepted
- Self-assessment is not sufficient under Level 2
Sources: https://www.nationaldefensemagazine.org/articles/2024/10/1/few-companies-ready-for-cmmc-compliance-study-finds, https://defensescoop.com/2023/12/28/cmmc-implementation-cost-estimates/
This disconnect shows how challenging the requirements are: companies may think basic cybersecurity measures are covered, but an in-depth third-party assessment often reveals critical gaps. The 110 controls span a wide range of practices – from access controls and encryption, to employee training, incident response, and physical security of IT systems.
Challenge for Aerospace Manufacturers
In Wichita alone, MLNavigator identified two MRO pilots specializing in military component overhaul who had not yet begun CMMC alignment in 2025 — despite handling CUI. Neither had a clear plan for air-gapped compliance tooling or documentation automation.
Implementing all requirements demands significant effort in technology, policies, and documentation. Smaller manufacturers and MROs face common gaps:
- Limited IT support
- Incomplete logging
- Ad hoc access control
- No audit trail tied to engineering activity
Yet the stakes are high: without at least CMMC Level 2, contractors will be barred from new DoD contracts under the upcoming rules, cutting off a major source of revenue. For aerospace MRO companies that service military aircraft or defense systems, CMMC compliance is as critical as quality compliance.
Just as a lapse in quality can lose a certification or customer, a lapse in cybersecurity can lose you a contract – or worse, lead to a breach that disrupts operations.
Categorized Breakdown of CMMC Controls
CMMC Level 2 Control Coverage
| Control | What it means | MLNavigator implementation | Status |
|---|---|---|---|
| Access Control | Role-based, system-level access. | Enforced at the time of upload; local authentication only. | Covered |
Audit and Accountability | Access, file-event, and activity traceability. | Immutable logs on the offline appliance. | Covered |
Configuration Management | Protection against tampering and unapproved changes. | The appliance is locked down and air-gapped. | Covered |
Identification and Authentication | Multi-factor authentication (MFA) and unique user IDs. | Admin-controlled local authentication. | Covered |
System and Information Integrity | Detection, reporting, and correction of errors. | Drawing intake and AI scanning pipeline. | Covered |
| Media Protection | Protection of digital engineering data. | On-device only; no cloud connectivity or storage. | Covered |
For a complete mapping of all 110 controls, request our compliance documentation.
Source: https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-171r2.pdf
How MLNavigator Helps
MLNavigator accelerates CMMC Level 2 readiness by:
- Providing an air-gapped compliance appliance with admin-controlled local authentication (Mac Studio or secure cluster)
- Enforcing role-based access controls on engineering documents
- Maintaining tamper-evident audit logs of drawing reviews and changes
- Performing AI-driven compliance scanning of uploaded drawings
- Operating entirely within your network boundary — no external connectivity or cloud storage
- Generating compliance reports for CMMC auditors and internal QA
By integrating quality management with cybersecurity hygiene, using DKS means your journey toward CMMC compliance is accelerated as a byproduct of improving your processes.
Business Impact
If CMMC is missed, aerospace MROs risk losing access to a $755 billion federal contracting market
MLNavigator's deployments begin at $10k–$75k, depending on scale — a fraction of typical compliance consulting + tooling bundles
MLNavigator enables a 50%+ error reduction, reducing audit risk and rework downstream
The fact that tens of thousands of suppliers must comply by 2026 means solutions that can streamline compliance will be in high demand. MLNavigator is positioned to help mid-sized aerospace firms get compliant faster and with less pain, by tackling the data and documentation aspects through automation.
Investor Note
CMMC compliance is not just a checkbox — it's a revenue prerequisite. With enforcement beginning in 2026, suppliers unable to certify will be disqualified from new DoD work. This creates a tailwind for vendors like MLNavigator who offer compliance acceleration as a service layer.
Our approach targets a 2–5× return via acquisition or revenue scaling, as outlined in our Series A roadmap. Compliance readiness will become a valuation multiplier in 2026–2028.
Next Steps
Start CMMC Preparation Now
- • Talk to us about deploying MLNavigator for your first site
- • Get a readiness evaluation in under 48 hours
- • Protect your eligibility — before enforcement closes the door
Request Demo
The clock is ticking toward 2026, but with the right tools and proactive effort, meeting the 110 practices of CMMC Level 2 is an achievable goal – one that will safeguard your business and ensure you continue to thrive in the defense supply chain.
Related Compliance Resources
For aerospace manufacturers and suppliers, CMMC compliance often runs parallel with other quality management requirements:
- Staying Audit-Ready in Aerospace: How MLNavigator Supports the AS9100D Cycle - Learn about maintaining continuous compliance with AS9100D throughout the 3-year certification cycle.
Conclusion
The 2026 deadline for CMMC Level 2 certification is approaching quickly. Waiting until the last minute means competing for limited C3PAO assessment slots and likely paying premium prices for rush implementations.