If 2025 felt like a whirlwind for regulatory compliance, you’re not imagining it. Between the finalization of Cybersecurity Model Maturity Certification 2.0 rules, the launch of FedRAMP’s 20x initiative promising faster authorizations, and new AI governance requirements from the Office of Management and Budget and the National Institute of Standards and Technology, organizations working with federal agencies faced enormous regulatory change.
As we head into 2026, the tempo isn’t slowing. The Defense Department is phasing CMMC into contracts to protect the defense industrial base. FedRAMP continues evolving as more agencies migrate critical systems to the cloud. And AI regulations are moving from principles to prescriptive requirements as governments grapple with the risks and opportunities of deploying AI at scale.
After leading hundreds of companies through compliance journeys and assessments — and going through them ourselves — we’ve learned that while each framework has nuances, three universal lessons apply.
Three lessons that apply to each framework
1) These frameworks are not like the ones you already know.
The biggest mistake? Treating CMMC like SOC 2 or assuming FedRAMP is “ISO 27001 for government.”
For example, CMMC Level 2 requires implementing all 110 NIST 800-171 requirements and 320 assessment objectives. Your system security plan alone could reach 200 pages. Budget more time, resources and specialized expertise than you think you need.
2) Scoping is a critical first step that organizations often get wrong.
Determining what’s in scope is one of the hardest and most important steps. I’ve seen companies believe 80% of infrastructure was in scope for CMMC, only to learn it was closer to 30%. Be ruthless about where controlled unclassified information actually lives. Every system you include can add months of work and tens of thousands in costs.
For FedRAMP, define your authorization boundary early. For AI governance, inventory every AI system, including embedded features in SaaS tools. Invest in scoping before implementing controls.
3) Automation is mission-critical, not optional.
Manual processes don’t scale when juggling multiple frameworks, and they leave you vulnerable to errors and inefficiencies. That’s why FedRAMP 20x and other frameworks today are evolving to put automation at the center of the process. Organizations that want continuous improvement must treat automation as core infrastructure, especially for monitoring controls, collecting evidence and surfacing real-time compliance data.
The real cost of playing catch-Up
Companies treating compliance as a last-minute sprint face hundreds of thousands of dollars in average costs for CMMC Level 2 alone. They scramble, rush documentation and often fail their first assessment — and non-compliance can come at a hefty price.
Organizations that delay addressing compliance gaps are vulnerable to security risks. IBM’s 2025 Cost of a Data Breach Report showed that noncompliance with regulations increases the average cost of a breach by nearly $174,000.
Regulatory actions are rising too. The Department of Health and Human Services’ Office for Civil Rights issued 19 settlements and over $8 million in fines for HIPAA violations this year to date, already the highest on record for a single year.
Organizations that start early spend less and use compliance as a competitive advantage. When you’re behind, compliance is a burden; when you’re ahead, it’s a differentiator.
What you need to know right now
For CMMC 2.0
If you’re a prime contractor, subcontractor handling CUI, or external service provider in the DoD supply chain, start now.
Identify what type of information you handle, what certification level you need, and define your scope. Build your system security plan early and categorize assets as CUI, security-protected, contract-risk managed or out of scope.
When selecting a C3PAO assessor, look for transparent pricing, strong references and clear data-handling processes. You can achieve conditional certification with a plan of action and milestones, but you have only 180 days to remediate and must score at least 80% in SPRS.
For FedRAMP 20x
Keep in mind that FedRAMP isn’t a one-time audit. The true 20x objective is not just to speed up authorizations, but to achieve smarter and stronger security — and this requires preparation.
These steps are non-negotiable:
Build continuous monitoring infrastructure and processes from day one.
Ensure your authorization boundary is correct and your architecture documentation is precise. Ambiguity causes delays that stretch timelines beyond a year.
Automate evidence collection and continuous monitoring for monthly deliverables required to maintain authorization.
For AI governance
Federal AI regulations are quickly moving from principles to requirements. Establish AI governance councils now. Inventory AI systems comprehensively, document training data provenance, implement bias testing protocols and create transparency mechanisms.
As OMB and NIST frameworks take hold, AI governance will become a standard procurement requirement through 2026.
Five steps to start today
1) Start with an honest gap assessment.
Most companies are further behind than they think, particularly on incident response and supply chain risk management. Know your baseline before building your roadmap.
2) Treat documentation like code.
Your system security plan, policies and authorization package shouldn’t be static Word documents. Your documentation needs to be a living architecture that is version-controlled, regularly updated and, ideally, machine readable.
3) Build compliance into procurement.
Create vendor risk assessment processes that evaluate CMMC readiness, FedRAMP authorization status and AI governance practices before signing contracts. For CMMC, ensure vendors provide Customer Responsibility Matrices documenting which NIST 800-171 controls they are responsible for.
4) Invest in your people.
Build exceptional compliance programs by upskilling existing staff. Send operations teams to CMMC training. Have developers learn secure coding for FedRAMP environments. Create AI literacy programs. Make compliance competency a core skill.
5) Prepare for continuous monitoring.
CMMC includes provisions for ongoing assessments and affirmations of compliance. FedRAMP requires continuous monitoring. AI governance demands continuous bias testing. Invest in automation systems and tools like trust centers that are able to demonstrate your up-to-date security and compliance posture any day of the year.
The opportunity in the complexity
Despite the challenges, companies getting compliance right are winning work they couldn’t before. Defense contractors and small businesses can use CMMC certification to compete for prime contracts. Cloud service providers who achieve FedRAMP authorization can significantly accelerate their federal sales cycles, cutting months from procurement timelines. AI startups land pilots by demonstrating responsible AI practices.
The companies that thrive treat compliance as something they control, not something that happens to them. They build security-first cultures, invest in the right tools and training, and transform compliance from cost center to competitive advantage.
The best time to start was yesterday. The second-best time is today, because 2026 promises even more compliance complexity, and it’s coming faster than you think.
Shrav Mehta is the founder and CEO of Secureframe.
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