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Are There Changes to Expect in CMMC Compliance Requirements by 2028?

The digital battlefield is shifting, and so are the rules that come with protecting sensitive data. Companies working with government contracts are being nudged toward smarter, faster, and more transparent cybersecurity practices. By 2028, what qualifies as “compliant” will likely look a lot different than it does today.

Anticipated Expansion of Zero-Trust Architecture Mandates

Zero-trust architecture has already entered cybersecurity discussions, but over the next few years, expect it to evolve from a suggested framework into a mandated foundation for meeting CMMC requirements. The basic concept—never trust, always verify—fits squarely within the goals of protecting Controlled Unclassified Information (CUI). Agencies are beginning to push harder for verifiable zero-trust models that limit internal and external threats by isolating data access and requiring constant validation.

This could mean a shift in how businesses structure internal networks. CMMC level 2 requirements already call for more stringent access control policies, but by 2028, the expectation may be a fully integrated zero-trust framework throughout your infrastructure. Organizations that haven’t yet embraced micro-segmentation, adaptive access controls, or continuous authentication will need to make significant changes ahead of their next CMMC assessment. These upgrades won’t just be technical—they’ll demand a company-wide change in mindset.

Stricter Integration of AI-Driven Threat Detection Systems

Artificial intelligence is no longer optional—it’s becoming essential. The next wave of CMMC compliance requirements is expected to raise the bar for proactive defense, with AI-driven systems taking center stage. Rather than reacting to incidents after the fact, AI and machine learning tools will be required to detect unusual behavior, flag anomalies, and mitigate risks in real time.

This means organizations will need to prove that their security systems can not only log activity but also actively respond to it. Current CMMC level 1 requirements don’t yet demand this level of automation, but as attackers grow more sophisticated, the compliance bar will rise. Integrating AI into your infrastructure means reevaluating existing tools, possibly replacing legacy systems, and ensuring the staff has training to work alongside intelligent monitoring systems. By 2028, it may be impossible to pass a CMMC assessment without some level of AI functionality embedded in your cybersecurity protocols.

Heightened Standards for Quantum-Resistant Encryption Adoption

With the development of quantum computing picking up speed, encryption standards are due for a major upgrade. Traditional cryptographic methods could become vulnerable in the not-so-distant future, and the Department of Defense is already watching closely. As CMMC requirements evolve, expect to see quantum resistance become a focal point for compliance, especially in higher levels.

This doesn’t mean organizations need to swap all encryption methods tomorrow, but by 2028, demonstrating a plan to migrate toward quantum-safe algorithms may be required. CMMC level 2 requirements could include testing environments or partial implementation of quantum-resistant protocols as part of a forward-thinking risk management approach. Encryption is the backbone of secure communications, and failing to adapt could expose systems in a post-quantum world.

Broader Implementation of Blockchain for Compliance Verification

Blockchain isn’t just for cryptocurrencies—it’s gaining ground as a tool for ensuring data integrity and transparency. In the context of CMMC compliance requirements, blockchain could serve as a secure, immutable ledger for logging access, tracking file changes, and verifying compliance across teams and partners. By 2028, its use in compliance reporting could move from novel to standard.

Adopting blockchain could simplify audits by offering a tamper-proof history of cybersecurity events and access logs. For companies preparing for a CMMC assessment, blockchain could also help demonstrate the integrity of supply chain data and internal controls. Expect broader adoption in both reporting and infrastructure components, particularly for contractors with complex vendor relationships or long product lifecycles.

Increased Requirements for Cybersecurity Transparency in Supply Chains

The supply chain is no longer just a logistical concern—it’s a cybersecurity one. As high-profile attacks have shown, even a single weak link can compromise an entire network. Future CMMC requirements are expected to demand much deeper insight into vendor security practices. It’s not just about your controls anymore—it’s about theirs, too.

Companies seeking certification will likely need to map out and assess the cybersecurity posture of all third-party suppliers and service providers. This may involve contractual requirements, third-party audits, or standardized reporting mechanisms. The era of blind trust is over, and future CMMC level 2 requirements could include shared responsibility models where each link in the chain must prove compliance. Organizations should be prepared to develop and maintain transparent, auditable records of vendor security practices.

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Mandatory Automation in Cyber Incident Response Protocols

Response time can mean the difference between a contained threat and a full-blown breach. Manual processes leave too much room for error and delay. That’s why automated incident response is expected to become a baseline requirement for future CMMC assessments. By 2028, playbooks and policies won’t be enough—automated execution will be key.

Organizations will need to demonstrate that their systems can isolate, contain, and notify relevant stakeholders the moment a breach attempt is detected. Whether through automated firewall rule adjustments or instant communication with response teams, the focus will shift from documentation to execution. For many businesses, this will require reworking current protocols and investing in orchestration platforms capable of meeting these expectations. This shift is particularly important as part of achieving long-term readiness under updated CMMC level 1 requirements.

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