CMMC Phase 2 Starts November 10: The Leadership Seat Defense Contractors Can't Leave Empty

On November 10, 2026, the Cybersecurity Maturity Model Certification program enters Phase 2. From that date, third-party CMMC Level 2 certification becomes a default requirement on many Department of Defense contracts that involve Controlled Unclassified Information. For companies in scope, being uncertified can mean being ineligible for award.

Most defense contractors have known this date was coming for more than a year. What many have not settled is who owns it. This brief looks at the leadership role behind CMMC readiness, and why boards and CEOs should treat it as a strategic hire rather than an IT backfill.

This is a perspective on leadership and hiring, not compliance guidance. Whether a given contract requires certification depends on the solicitation and its clauses, and companies should rely on their own counsel and assessors for that.

Why this has become a leadership question

For years, cybersecurity compliance in the defense industrial base sat in one of two places: an overextended IT director, or a consultant who arrived before an audit and left after it. Self-attestation made that model workable.

Third-party certification changes the math. An external assessor tests whether controls work in practice, across people, systems and suppliers. Certification lasts three years, with annual affirmation in between, so readiness is no longer a project. It is an operating discipline, and it needs an owner with authority across the business.

Capacity adds pressure. Industry estimates of assessor availability suggest that demand for assessments far exceeds supply, and some contractors report long waits. Companies that start late have less room to recover from a failed assessment.

What the role looks like

The title varies: CISO, VP of Cybersecurity and Compliance, Director of CMMC Programs. The mandate is consistent. The leader is accountable for:

• Readiness: scoping CUI, closing gaps against the required controls, and keeping the system security plan current
• Assessment: selecting and managing the third-party assessor relationship, and owning remediation
• Supply chain: making sure subcontractors that handle CUI can meet their own requirements, because a prime's exposure doesn't stop at its own network
• Continuity: maintaining compliance between assessments and owning the annual affirmation
• Business alignment: telling capture and program leaders which opportunities the company can credibly bid on

Five questions to settle before the search

Searches for this seat stall for the same reason as most executive searches: the mandate was never agreed. Before outreach begins, leadership should answer:

1. Who does the role report to? Reporting to the CEO, COO or general counsel signals that compliance is a business risk. Reporting deep inside IT signals the opposite, and strong candidates notice.
2. What authority comes with it? Can this leader stop a system going live, require a supplier to remediate, or block a bid that the company cannot support?
3. What is in scope? Enterprise IT only, or also engineering environments, manufacturing systems and program enclaves?
4. What does success look like at 12 months? Certification achieved, a defined remediation plan, a supplier program in place?
5. What budget and team are already committed? Candidates will ask, and vague answers cost you the best of them.

Traits of leaders who succeed

The candidates who do well in this seat tend to share four traits:

• Defense fluency. They understand how CUI moves through programs, not just through networks.
• Assessment experience. They have led an organization through a formal external assessment and know what assessors look for.
• Commercial judgment. They can translate compliance status into bid decisions without becoming the department that always says no.
• Influence without control. Much of the work happens in engineering, operations and suppliers that don't report to them.

Where they come from

The talent pools are familiar but thin: security leaders at primes and tier-one suppliers, former assessors and advisory partners, program-side leaders with deep information assurance backgrounds, and federal or military cyber leaders moving into industry. Each brings trade-offs in commercial experience, scale and culture. In our experience, the strongest candidates are already employed and are not looking, which is why a confidential, partner-led approach matters.

The bottom line

November 10 is a date on a compliance calendar, but the decision it forces is a leadership one. Companies that put an accountable, empowered executive in this seat will treat certification as an advantage in capture. Companies that leave it to an overextended team will find out where they stand when an award goes elsewhere.

Nexoval Search Partners leads confidential executive searches in Aerospace & Defense, Advanced Manufacturing and Technology & AI. For a confidential conversation about a cybersecurity or compliance leadership search, contact admin@nexovalgroup.com.