Update: On July 13, 2026, the Department of War suspended CMMC Phase 2, pausing the mandatory third-party (C3PAO) assessments that were scheduled to begin November 10, 2026, while a task force conducts a 60-day review of the program. Level 1 and Level 2 self-assessments submitted to SPRS, the 110 NIST SP 800-171 controls, and DFARS 252.204-7012 obligations all remain mandatory. This article has been updated to reflect these changes.
If you run a manufacturing company that does business with the government or other large government suppliers, security audits are now a normal part of sales and contracting. The Cybersecurity Maturity Model Certification (CMMC) is in its first phase of enforcement, with the government and major vendors requiring it in new contracts.
In July 2026, the DoD suspended the planned November 2026 rollout of mandatory third-party assessments while it conducts a review of the CMMC program. The underlying requirements have not changed. Applicable contracts still require Level 1 and Level 2 self-assessments submitted to SPRS, the 110 NIST SP 800-171 controls remain a contractual obligation, and prime contractors are still sending security questionnaires that demand proof of compliance.
To keep revenue flowing, manufacturers and suppliers need to act.
The hard truth is that most manufacturers are not ready, and most cannot afford to hire full-time security and compliance personnel to get there. That is exactly the gap a vISO fills.
What Is a vISO and Why Should a Manufacturer Care?
Standing apart from a singular virtual CISO, Vancord’s virtual Information Security Office or vISO is a full team of security experts that boosts your company’s security leadership and operations. They are not a software tool, and they are not a one-time consultant who renders opinions and leaves. They learn your business and its needs, help define and track security priorities, guide compliance efforts, coordinate with auditors, and ensure security decisions support business goals.
For manufacturers, this matters because the compliance pressure has gotten very real, very fast. Manufacturing accounted for 27.7% of all cybersecurity incidents in 2025, making it the most targeted industry for the fifth year in a row based on this article from IBM. To the Department of War, this is a threat against defensive and offensive preparedness as adversaries target the privacy sector.
According to former DoD CMMC leader Katie Arrington, only 1% of Defense Industrial Base companies have implemented all 110 NIST SP 800-171 controls that form the foundation of CMMC Level 2 compliance. That means many manufacturers still have significant work to do before they are ready for future assessments, customer audits, and contract requirements.
Vancord’s vISO and Security Program Development services were built specifically to close that gap, without requiring you to post a six-figure job listing for a CISO. Manufacturers can also explore Vancord’s Manufacturing industry resources to better understand the cybersecurity, compliance, and operational challenges facing today’s industrial organizations.
The Three Audits Manufacturers Are Dealing With Right Now
| Requirement | Who Requires It | What It Focuses On | Why It Matters |
|---|---|---|---|
| CMMC 2.0 | Department of War | Protection of CUI | Required for many defense contracts |
| NIST 800-171 | Government agencies and contractors | 110 security controls | Foundation for CMMC Level 2 |
| SOC2, ISO27001, and customer security requirements | Customers and supply chain partners | Security maturity and risk management | Impacts contract renewals and new business |
CMMC 2.0: The Defense Contract Requirement
If your business handles Controlled Unclassified Information (CUI) for the Department of War, you fall under CMMC Level 2. CMMC 2.0 enforcement began with Phase 1 on November 10, 2025, requiring Level 1 and Level 2 self-assessments in applicable contracts. Phase 2, which would have required third-party C3PAO-assessed Level 2 status beginning November 10, 2026, was suspended in July 2026, along with all future rollout milestones, pending a 60-day DoD program review. Self-assessment requirements remain fully in force, and contracting officers have been directed to amend solicitations that already included the suspended Phase 2 requirements.
The average manufacturer requires 6 to 12 months to reach audit readiness, and the suspension does not change that math, it changes what you are getting ready for. Your SPRS self-assessment score is backed by a signed affirmation of compliance from a senior company official, which carries real legal exposure if it is inaccurate. And whatever framework emerges from the DoD’s review will still be built on NIST 800-171, so preparation done now is not wasted. A vISO keeps that preparation moving on a realistic timeline.They know how the 110 NIST 800-171 controls could apply to your environment, what evidence auditors actually want to see, and how to build the documentation that gets you through an assessment — whether that is your own SPRS self-assessment today or a third-party review if C3PAO requirements return. Vancord’s privacy and compliance audit services are built around exactly this kind of structured readiness work.
If you are still sorting out whether CMMC applies to you, the earlier Vancord post on who needs CMMC certification is a good starting point.
NIST 800-171: More Than Just a CMMC Prerequisite
NIST 800-171 is the 110-control security framework that CMMC Level 2 is built on. But it also shows up on its own in state contracts, federal civilian contracts, and increasingly in terms and conditions from large prime contractors. Even manufacturers who are not chasing a DoD certification are finding these controls referenced in the contracts they already have.
Working through 110 controls without someone who knows the material is slow and expensive. A vISO team has done this dozens of times. They know which controls are easy wins, which ones require real infrastructure work, and how to prioritize so you are not spending three months on something that takes a week when done correctly.
Customer Security Questionnaires and Vendor Audits
This third category does not make as many headlines as CMMC, but it is often what triggers the first real security conversation inside a manufacturer. A Tier 1 automotive customer sends a 200-question security survey. A large aerospace client says they need to audit your facility before renewing the contract. A healthcare company wants proof that your quality management systems are secured before they approve you as a supplier.
These are not government requirements. They are business requirements. And failing them costs contracts.
A vISO helps you build the policies, procedures, and evidence that answer these questionnaires honestly and completely. They also help you run a security gap analysis before a customer does, so there are no surprises.
What a vISO Actually Does to Prepare You
Day-to-day work for a vISO in a manufacturing environment usually covers four main areas.
First, they figure out where you stand. That means reviewing your current security controls, identifying what is missing, and building a realistic plan to close the gaps. This is similar to what Vancord calls a cybersecurity readiness and risk assessment, and it is almost always the first step.
Second, they build and maintain the documentation. CMMC and NIST auditors do not just want you to have security controls in place. They want a System Security Plan (SSP), a Plan of Action and Milestones (POA&M), written policies, and evidence of ongoing practices. Most manufacturers do not have these documents. A vISO team builds them and keeps them current.
Third, they prepare your people. Security awareness is one of the most commonly flagged areas in manufacturing audits because shop floor employees and office staff often have very different habits around things like password use, email, and removable media. Vancord’s security awareness training is something a vISO can plug directly into your workforce, not as a one-time exercise but as an ongoing program.
Fourth, they get you ready to test your own defenses before an auditor does. Tabletop exercises let your leadership team walk through a cyber incident on paper to find the gaps in your response plan. Vancord’s tabletop and incident response testing is specifically designed to surface the things you would not think of until it is too late.
Why Manufacturers Specifically Benefit From a vISO Over a Hire
Hiring a full-time CISO with compliance expertise at a manufacturing company typically costs $200,000 to $300,000 a year in salary alone, before benefits, tools, or support staff. Even a fractional CISO is often a single person with a single perspective. As discussed previously at fractional CISO vs. vISO services, a vISO team brings a broader bench of expertise, across compliance, risk, technical security, and audit preparation, for a fraction of that cost.
For a mid-size manufacturer running 50 to 500 employees, that difference is material. You get senior-level security guidance without the headcount, and the team scales with you as your compliance requirements grow. The piece on when a company needs a virtual CISO goes deeper on this if you are still weighing the decision.
Frequently Asked Questions
Do I need a vISO if I already have an IT team?
Yes, in most cases. IT teams manage your systems, but CMMC and NIST 800-171 require security governance, written programs, and audit-ready documentation that most IT staff are not trained or resourced to produce. A vISO fills the leadership layer above your IT team, or supports existing leadership with overloaded responsibilities by acting as a pressure relief valve.
How long does it take to get audit-ready with a vISO?
It depends on your starting point. Organizations starting with little documentation typically need six to twelve months of focused work to build a mature cybersecurity program, complete required documentation, and prepare for current self-assessments or future CMMC assessment requirements. Starting sooner gets you there faster.
Will a vISO represent us during an actual audit?
Yes. A vISO team supports you through the assessment process, helps coordinate with auditors, and responds to findings. They do not disappear at the finish line.
Is a vISO the same as an MSSP?
Not exactly. An MSSP monitors your environment around the clock. A vISO focuses on security leadership, program development, and compliance. Vancord provides both, and the two services work well together. You can learn more about Vancord’s full managed security services to see how the pieces fit.
How much does a vISO cost compared to hiring a CISO?
Hiring a full-time Chief Information Security Officer (CISO) can cost $200,000 or more annually before benefits and bonuses. A vISO provides strategic security leadership at a fraction of that cost while giving organizations access to a broader range of expertise.
Has CMMC been canceled?
No. In July 2026, the Department of War suspended the planned rollout of Phase 2, including mandatory Level 2 third-party assessments, while conducting a review of the program. Existing Phase 1 implementation, applicable self-assessments, NIST SP 800-171 security requirements, and DFARS cybersecurity obligations remain in effect. Organizations should continue strengthening their cybersecurity programs and monitor future DoD guidance.
Preparing for CMMC, NIST 800-171, and Customer Audits Starts Now
Many manufacturers know they need to improve cybersecurity, but they are not sure where to begin. Others have started working toward compliance but struggle with documentation, policy development, risk assessments, or understanding what auditors will actually expect to see.
The reality is that preparing for CMMC, NIST 800-171, and customer security audits takes more than technical controls. It requires a structured security program, clear documentation, ongoing oversight, and a plan that aligns with your business goals.
That is where a vISO can help.
Vancord works with manufacturers to assess security gaps, build compliance roadmaps, develop security policies, prepare audit documentation, and strengthen overall cybersecurity readiness. Whether you are just starting your compliance journey or preparing for an upcoming assessment, our team can help you take the next step with confidence.
Contact Vancord today to discuss your compliance requirements and learn how a vISO can help your organization prepare for CMMC readiness, implement NIST SP 800-171 security requirements, respond to customer security audits, and adapt to future Department of War cybersecurity requirements.