Mastering the Compliance Maze: FAR and CMMC Compliance for 2026

Three people talking over each other. Sudden bursts of debate. Hot takes flying back and forth like we were reviewing game-winning plays. Sounds like the latest episode of SportsCenter, right? Turns out it was our latest webinar.

Honestly, the comparison fits. FAR and CMMC compliance is a kind of deadly serious football game.

The field is enormous, the rulebook keeps changing, and the referees (a.k.a. federal agencies) are watching every move. One bad formation in your SAM.gov setup, and you don’t even get to step on the field. Miss a blocking assignment in your SPRS score, and the play collapses before it starts. Every contract is a high-stakes drive, and the teams that win are the ones that study the film, know the strategy, and execute with discipline.

That’s why you want commentary from people who know the playbook inside-out: players who have been hit hard in real audits, taken the sack, learned from it, and can read the defense before the snap. That was the energy on the call: fast, dynamic, a little chaotic, and laser-focused on helping contractors avoid turnovers as 2026 approaches.

The panel featured Luke Voivoda and Shahid Shah, with Kyle McClain moderating. Luke is a seasoned federal business development leader at Ace BD who guides small and mid-sized contractors through the full acquisition lifecycle, specializing in translating FAR rules into winning proposals. Shahid is an internationally recognized cybersecurity and risk-management expert and architect of major OMB and DoD security initiatives who now helps organizations turn CMMC requirements into clear, practical security programs.

This article captures the core ideas from the session so you can understand the state of the landscape, clarify your obligations, and take concrete steps toward 2026 readiness.

FAR Compliance in Plain English: The Three Pillars

The Federal Acquisition Regulation was implemented in the early 1980s to unify federal procurement rules into a single, government-wide framework. Its goal is to ensure federal buying is fair, transparent, and risk-controlled, no matter which agency is awarding work.

The FAR’s structure reflects the lifecycle of contracting itself: who is eligible, how proposals must be evaluated, and how performance is overseen. Although the regulation is undergoing its most significant modernization in decades, the foundational logic remains the same: reduce risk for the government by enforcing consistent, documented processes for vendors.

With that framing in place, FAR compliance becomes much easier to understand. It breaks down into three practical layers.

1. Existential Compliance: Are You Even Allowed to Play?

Before you write a proposal or pursue a subcontract, you must be visible and valid in federal systems:

Active SAM.gov registration
Valid UEI and CAGE code
Current and accurate reps & certs

These steps don’t win contracts; they establish your legal existence as a federal vendor.

2. Contract-Winning Compliance: Are You Submitting a Compliant Proposal?

Under FAR Part 15, your proposal must follow:

Section L instructions
Section M evaluation criteria

Clarity, clean formatting, compliant pricing structures, and responsiveness are the real differentiators. This is where inconsistencies or omissions can knock you out of the competition before evaluation even begins.

3. Post-Award Compliance: Can You Keep What You Win?

FAR Part 42 governs contract administration: how you perform, communicate, and handle government data after award. It sets expectations around:

Documented procedures
Subcontractor oversight
Incident response
Change management
Physical and logical security
Coordination with the CO/COR

Across all these layers, one idea dominates: document everything. You’re likely doing most of what FAR expects already. Just be sure to write it down and store it in one place.

CMMC: Doors, Knobs, Locks—and How It Actually Works

CMMC exists to ensure contractors protect the data the government entrusts to them. While it grew out of DoD concerns, its logic is universal: small, unclassified leaks can combine into strategic intelligence for adversaries.

The result is a standard that asks companies to prove that their digital and operational environment is minimally trustworthy.

A simple analogy captures its essence:

CMMC requires doors (baseline safeguards)
Those doors need knobs (procedures for access)
The knobs need locks (technical controls)
And the locks must actually be locked (evidence and practice)

A Brief History and Purpose

CMMC originated from longstanding challenges inside the defense supply chain. Despite earlier frameworks such as NIST SP 800-171, contractors routinely self-attested to compliance without sufficient evidence. The attack surface was enormous, with hundreds of thousands of vendors, many small, many under-resourced.

CMMC emerged to solve the “trust but verify” problem and ensure contractors at every tier maintain basic cybersecurity. It aligns directly with national defense goals: safeguarding FCI and CUI so adversaries cannot exploit gaps between prime contractors and small subs.

Levels and Expectations

CMMC Level 1 covers “basic cyber hygiene” for protecting FCI and is covered by a self-assessment.
CMMC Level 2 aligns with NIST SP 800-171 for organizations handling CUI and often requires third-party assessments.
CMMC Level 3 addresses high-priority critical programs and is directly assessed by the DoD.

How CMMC Works in Practice

To comply with CMMC Level 1, contractors must do more than adopt controls. They must attest to their status and submit evidence in the government’s systems.

The basic workflow is:

Assess your environment Determine whether you handle FCI or CUI, and identify your required level.
Implement the applicable controls This includes policies, procedures, technical safeguards, and documentation.
Submit your score to SPRS (Supplier Performance Risk System) For Level 1, self-attestation will also be required in SPRS as enforcement ramps.
Undergo assessment if required Level 1 will be self-attested, while Level 2 may require a C3PAO third-party audit depending on contract requirements.
Maintain evidence continuously Evidence must be current and auditable (this is where most organizations struggle).

In short, CMMC is not just a policy checklist; it’s an evidence-driven assurance model with real submission pathways and real penalties for inaccuracies.

Where FAR and CMMC Intersect

Although FAR and CMMC speak different languages, they meet at the same destination: reducing risk for federal missions.

The easiest way to understand their relationship is this:

FAR sets the rules of the game.
CMMC secures the stadium where the game is played.

FAR determines whether you can participate and how proposals must be written. CMMC determines whether the government can trust you with its information. Seen this way, the two frameworks reinforce each other rather than compete for your attention.

However, contractors often ask which one should be addressed first. The practical sequence looks like this:

1. Start with the existential FAR requirements. If your SAM.gov registration has lapsed, nothing else matters. Get your UEI, CAGE code, and reps & certs in order before pursuing any compliance program.

2. Treat CMMC Level 1 as mandatory for defense work. If you are in the DoD ecosystem, CMMC Level 1 is a prerequisite for new contracts and renewals. Submitting accurate scores in SPRS is part of that readiness.

3. Build shared systems that support both. Both FAR and CMMC rely on documentation, repeatability, and audit readiness. A centralized evidence warehouse supports:

FAR Part 15 proposal submissions
FAR Part 42 post-award oversight
CMMC evidence packages
SPRS reporting
Subcontractor management
Internal audits and external assessments

Approaching compliance through a unified operational system prevents duplication and makes both frameworks far more manageable.

From One-Time Project to Ongoing System

The most significant shift contractors must make is recognizing that neither FAR nor CMMC can be handled as episodic projects. The era of last-minute audit preparation is ending.

The federal government is rapidly moving toward AI-driven oversight. Systems like Palantir and C3 allow agencies to digest large volumes of contractor evidence in seconds. Over time, contractors will be asked to provide standardized, machine-readable evidence bundles, not high-level narratives.

This future rewards organizations that:

Maintain documentation continuously
Update policies as environments evolve
Capture decisions and approvals as they happen
Use AI internally to validate and pre-check evidence
Treat audit readiness as an everyday operational norm

Continuous compliance becomes the path of least resistance once your evidence and practices live in a single structured system.

Key Takeaways

FAR and CMMC are converging into a shared expectation: risk-aware, evidence-backed operations.
Your SAM.gov posture is foundational. Without it, nothing moves.
CMMC Level 1 is now table stakes for contractors anywhere near the defense supply chain.
Most companies already do much of the required work; the missing piece is documentation and organization.
Compliance will become AI-assisted and evidence-driven, making continuous readiness the new standard.
Modern tools dramatically shorten the path to clarity, helping contractors assess, document, and remediate far more efficiently.

Watch the Webinar and Start Your Readiness Journey

To see these principles in action (and to watch a CMMC self-assessment workflow in real time) view the full webinar recording and Opsfolio demo.

Mastering the Compliance Maze

A Webinar about FAR and CMMC Compliance.

1:00:36

From there, you can:

Complete your own Level 1 assessment
Generate customized policies
Consult Opsfolio to learn how to build your evidence warehouse and establish a clear roadmap toward full FAR and CMMC readiness

The contractors who thrive through the 2026 transition will be those who build clarity, structure, and trust into their operations today.