COMMENTARY: What Security Leaders Do Now in Wake of CMMC Pause

The US Department of Defense suspended CMMC Phase 2's third-party assessment requirement in July 2026, but this removes the independent verification layer whilst NIST SP 800-171 compliance obligations remain unchanged. Security leaders now face heightened personal liability under the Justice Department's Civil Cyber-Fraud Initiative, which has settled 15 cases since 2021, with no breach required—only a mismatch between attestation and actual environment. You just lost the auditor but kept the audit. The compliance requirement you were outsourcing to a third party is now your personal signature on a False Claims Act document—and Justice has settled 15 cyber-fraud cases since 2021 with zero breaches required, just a gap between what you claimed and what your logs show.