Who Needs CMMC 2.0?
What you need to know
Who Needs CMMC 2.0?
For many Australian businesses, CMMC 2.0 still feels like something that only applies to US companies. The reality is very different. If your organisation works with, or plans to work with, the US Department of Defense (DoD) or its contractors, then CMMC is a requirement you cannot ignore.
The question isn’t whether CMMC applies to Australians — it’s whether you want access to one of the largest defence markets in the world.
Understanding Who CMMC Applies To
CMMC applies to any organisation that handles either of the following for the US DoD:
Federal Contract Information (FCI): Information not intended for public release, provided by or generated for the government under a contract.
Controlled Unclassified Information (CUI): Sensitive information requiring protection, such as technical data, engineering specifications, or operational information.
This means CMMC is not limited to prime contractors in the United States. It extends through the entire supply chain, covering subcontractors and service providers worldwide.
Australian Businesses In Scope
CMMC matters to a growing list of Australian organisations. For example:
Engineering and Design Firms providing technical drawings or models for US Defence projects.
Technology Companies delivering software, hardware, or systems that integrate into US Defence platforms.
Logistics Providers moving or managing sensitive goods in support of Defence contracts.
Specialist Consultancies engaged by US primes to deliver advisory or niche services.
Even if your work is a few steps removed from the US DoD itself, if you’re part of a supply chain that involves FCI or CUI, certification can still be required.
Why This Matters for Australia
Australia’s defence sector is deeply tied to the United States through the AUKUS agreement, joint training, and cooperative supply chains. Increasingly, Australian companies are being tapped to deliver specialised capability. But without CMMC, many of these opportunities are inaccessible.
For businesses that already hold DISP membership or ISO 27001 certification, CMMC may feel redundant. In practice, it isn’t. Each framework serves a different audience:
DISP protects Australian Defence information.
ISO 27001 demonstrates global best practice.
CMMC is the entry ticket to the US DoD supply chain.
The Risks of Inaction
If your business touches US Defence projects — even indirectly — failing to pursue CMMC carries real consequences:
Lost opportunities: Without certification, you may be excluded from tenders.
Contract disruption: If your prime contractor requires CMMC compliance, you risk being dropped as a supplier.
Strategic isolation: As more contracts include CMMC, non-certified businesses may find themselves sidelined in favour of competitors who took the early steps.
Why External Expertise is Required?
CMMC 2.0 compliance is rarely a straightforward exercise. Australian businesses face three particular challenges:
Interpreting US Standards: NIST 800-171 requirements can be highly detailed, and mapping them correctly to your existing environment takes specialist knowledge.
Bridging Frameworks: Understanding how DISP and ISO align with CMMC prevents duplication of work and wasted effort.
Certification Pathways: Assessment must be conducted by accredited US bodies. For Australian companies, navigating that process without established connections can be daunting.
These realities make external expertise essential. Independent specialists help identify what truly applies to your business, streamline the compliance effort, and guide you toward a certification pathway that is achievable and commercially sensible.
CMMC is not just an American challenge. For Australian businesses working in the defence sector, it is becoming a baseline requirement to access and remain in the US supply chain. Whether you’re an engineering firm, a software provider, or a logistics operator, if your work involves US Defence information, CMMC is likely to apply.
Early action is the smartest move. By understanding who needs CMMC, and why external expertise is often required, Australian businesses can position themselves for growth, resilience, and long-term relevance in a rapidly changing defence landscape.
Where to Start?
Most businesses benefit from starting with an Essential 8 assessment to understand their current maturity level and identify priority actions. From there, you can create a targeted uplift plan to reach your compliance and security goals.