Gabrielle Long

The Department of War (“DoW”) has put an immediate hold on the next phase of Cybersecurity Maturity Model Certification (“CMMC”) implementation.

[co-author:Lauren Tesler] Key Takeaways for Business Operators: Current 8(a) participants: The proposed rule should not disrupt current certification status or the next annual review. Prospective applicants: Expect a more evidence-driven application process that may require more preparation time and internal coordination.

[co-author: Lauren Tesler] Context On April 30, 2026, the White House issued a highly consequential Executive Order (“EO”) titled “Promoting Efficiency, Accountability, and Performance in Federal Contracting.” This EO fundamentally alters the federal procurement framework by establishing fixed-price and performance-based contracts as the default mechanism for government acquisition, moving sharply away from historical cost-reimbursement and time-and-materials models.