Vigilant Cybersecurity

CMMC Weekly Briefing · Aug 17–21, 2026

CUI marking emerges as the reform issue everyone agrees on

Top story

As the RFI comments became public, one problem stood out: the government's own handling of controlled unclassified information. Federal News Network's report on the CMMC review opens: "Most organizations agree a key problem for the CMMC program is the Defense Department's inability to properly identify and mark CUI." NDIA's comments warned that "Without addressing the underlying CUI program, the current inconsistent marking process will continue to lead to increased costs and burdens on industry and degraded security for department information." Kate Growley of Crowell & Moring summed up why it matters: "CMMC follows the data. If CUI is being over- or under-scoped, so will the scope of CMMC."

Rules and policy

  • SBA Advocacy posts its comments. On August 17 Advocacy published a summary of its August 14 letter: "Reform should clarify and right-size requirements, not weaken them, focusing on high-value controls like MFA, least-privilege access, encryption, segmentation, incident response, and training." Why it matters: even the small-business advocate is asking for better targeting, not a lower bar.
  • "Brilliant at the Basics." A CMMC.com analysis published August 18 looks at the DoW CIO's voluntary awareness campaign, launched July 13 alongside the pause. The first item on its list: "Upgrading legacy methods to phishing-resistant multi-factor authentication." Why it matters: the CIO's priority controls are a reasonable preview of what a reformed CMMC will emphasize.

Industry and enforcement

  • No DOJ cyber-fraud settlements were announced this week.

Still on the radar

  • The task force's 60-day review, ending about September 11, with its report expected about 15 days later.
  • The DIB Accelerator in Philadelphia, August 25–27.

Watch list

  • Any DoW summary of the RFI responses.
  • Personnel changes in the DoW CIO's office.

What to do this week

  • Review how CUI reaches you: which contracts, which markings, which people. If markings are inconsistent, document it and ask your contracting officer.
  • Move to phishing-resistant MFA where you can. It tops the CIO's list for a reason.

Sources

This briefing summarizes public sources for general awareness. It is not legal advice. Check the linked primary sources before acting on any item.

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