CMMC, DFARS, and Construction: What Owners and Contractors Need to Know in 2026

Construction organizations that touch U.S. Department of Defense (DoD) programs are operating in a security environment that looks less like traditional “IT compliance” and more like supply chain risk management. Two frameworks sit at the center of this shift: DFARS cyber clauses (which govern contractual cybersecurity requirements for defense contractors) and the Cybersecurity Maturity Model Certification (CMMC) program (which is DoD’s mechanism for validating that those requirements are actually implemented). In 2026, owners, prime contractors, specialty trades, and design partners will increasingly encounter cybersecurity obligations that extend beyond corporate networks into project workflows, document exchanges, submittals, RFIs, schedules, pay apps, and field reporting.

This post explains what DFARS and CMMC are, why construction is uniquely exposed, what “CUI” looks like in real construction terms, how requirements flow down to subcontractors, and how to reduce risk with practical controls and a connected project collaboration model that keeps sensitive data inside the authorized security boundary.

1. Introduction: Why Construction is in Scope

Historically, construction cybersecurity conversations focused on business continuity, ransomware, and basic IT hygiene. Defense construction changes the equation. Facilities programs can involve sensitive site data, operational constraints, and mission-related information that becomes regulated once it is designated as Controlled Unclassified Information (CUI). At the same time, project delivery relies on multi-stakeholder collaboration. Owners, architects, engineers, general contractors, construction managers, and specialty subcontractors all exchange documents and updates continuously. That creates a large attack surface and a high likelihood of unintentional data handling failures, especially when teams rely on disconnected tools and ad hoc file sharing.

DoD’s approach is straightforward: if you handle sensitive information for a defense program, you must implement standardized safeguards and prove it. DFARS establishes many of the contractual obligations, while CMMC is the verification mechanism that scales those obligations across the defense industrial base and the contractor supply chain.

2. Key Definitions and Concepts

2.1 DFARS in plain terms

DFARS is the Department of Defense supplement to the Federal Acquisition Regulation (FAR). For cybersecurity, DFARS clauses commonly appear in contracts when a contractor will process, store, or transmit sensitive information tied to DoD programs. In practice, DFARS clauses define the expectations for protecting covered data, reporting cyber incidents, and ensuring that suppliers meet applicable requirements when data flows downstream.

2.2 CUI in construction terms

CUI is not a single document label. It is a category of information that the U.S. government has determined requires safeguarding or dissemination controls. In construction, CUI can show up in places teams do not expect, including:

• Facility drawings and specifications tied to mission systems
• Site security plans, access control procedures, guard schedules
• Network, communications, and building automation design details
• Incident reports and vulnerability findings
• Asset inventories, equipment lists, and commissioning documentation
• Requests for Information that reveal protected details about the site

A critical point for 2026 planning is that the same file can shift into scope based on context. A drawing set for a standard municipal building is not automatically sensitive. A drawing set for a defense installation project may become CUI depending on designation and content.

2.3 CMMC’s role

CMMC exists because self-attestation has not consistently produced the level of protection DoD expects across its supplier ecosystem. CMMC is designed to formalize and validate the implementation of security practices. For construction organizations, this matters because project teams are often part of the DoD supply chain even if “construction” is not the first thing people associate with defense contracting.

3. Why Multi-Stakeholder Project Delivery Creates Cybersecurity Risk

3.1 The collaboration paradox

Modern projects succeed when information is shared quickly. Cybersecurity succeeds when information is controlled carefully. Multi-stakeholder delivery forces those two truths into daily conflict. Common productivity patterns can create compliance problems:

• Emailing drawings and attachments
• Using public file links that bypass access controls
• Downloading and re-uploading files into separate systems
• Duplicating logs, submittal registers, or pay application backups in spreadsheets
• Allowing uncontrolled vendor “shadow IT” for scheduling, RFIs, or closeout

These are not edge cases. They are normal behaviors on projects that do not have a single governed collaboration environment.

3.2 Downstream exposure

On a typical project, the prime may implement robust corporate security while specialty trades use consumer-grade tools. DFARS and CMMC pressures increasingly shift risk management from “your company” to “your network of companies.” From an owner’s perspective, the weakest link can compromise the entire program. From a prime contractor’s perspective, a subcontractor that cannot meet requirements can become a schedule risk, a bid risk, and a compliance risk.

4. What Owners Need to Know in 2026

4.1 Procurement language will drive outcomes

Owners influence the security posture of a program primarily through contract requirements and operational expectations. If procurement language is vague, teams will fill the gaps with convenience tools. If language is specific, owners can structure compliance without turning projects into paperwork.

Owners should ensure solicitations and contracts clearly address:

• What data is designated as CUI and how designation will be communicated
• Whether CUI is expected to be created during the project
• Required safeguarding expectations for systems used to store or transmit CUI
• Rules for file sharing, external access, and collaboration
• Expectations for incident reporting and coordination
• Flow-down requirements for design partners, CM/GCs, and subcontractors
• Evidence required at project milestones (for example, audit logs, access history, and retention expectations)

4.2 Owners should reduce scope wherever possible

A major driver of cost and complexity is “scope creep” in what systems are used for in-scope data. Owners can reduce program risk by:

• Minimizing the number of platforms where CUI resides
• Standardizing a secure collaboration environment
• Avoiding workflows that require contractors to download and duplicate data into uncontrolled systems
• Establishing a clear boundary between in-scope and out-of-scope systems

4.3 Validate operational reality, not just policy

Security policies can look excellent while jobsite reality remains uncontrolled. Owners should look for evidence that:

• Access is role-based and tied to the project team structure
• External sharing is governed
• Audit logs exist for file access and key actions
• The platform supports reporting and export for audits without encouraging bulk extraction of sensitive data
• Retention and backup practices align with the owner’s requirements

5. What Contractors Need to Know in 2026

5.1 CMMC readiness is a bid strategy, not a back-office task

Even before certification requirements fully propagate through every construction program, owners and primes will increasingly treat cybersecurity as a qualifier. Contractors should plan for:

• Pre-qualification questions on security controls and CUI handling
• Contract clauses that explicitly restrict tools and sharing methods
• Increased scrutiny on how subcontractors will access project information
• The need to provide evidence quickly during audits or incident investigations

5.2 Understand where your project workflows touch CUI

Contractors should map their end-to-end workflows and identify where CUI may be created, stored, or transmitted. Typical hotspots include:

• Drawing and specification distribution
• RFI responses and design clarifications
• Submittals and product data tied to security systems
• Field reports, daily logs, and incident documentation
• Closeout deliverables, commissioning records, and asset documentation
• Meeting minutes that include security topics

This mapping becomes the foundation for deciding which systems must be in-scope and which can remain out-of-scope.

5.3 The subcontractor problem must be addressed early

A recurring failure mode is discovering late that a key specialty trade cannot meet cybersecurity requirements. In 2026, contractors should treat this the same way they treat bonding, safety qualifications, and insurance:

• Identify which subcontractors will touch sensitive deliverables
• Establish clear rules for access and collaboration
• Provide a secure project environment so subcontractors do not need to download and re-enter sensitive data
• Use role-based permissions and scoped access so subcontractors only see what they need

6. Practical Implementation: What “Good” Looks Like on a Project

6.1 Governance: one platform, one source of truth

Multi-stakeholder projects fail cybersecurity when each company runs its own siloed system and data must be copied between them. A better model is a connected project environment that:

• Centralizes project records, forms, and files
• Enforces permissions consistently across organizations
• Preserves audit trails without manual effort
• Reduces duplication and uncontrolled exports

6.2 Controls that matter in day-to-day construction

Without turning this into a checklist of security frameworks, construction organizations should focus on controls that directly reduce common project risks:

• Role-based permissions for forms, files, folders, workflows, and reports
• Strong identity and access management practices
• Controlled sharing that does not allow anonymous public links
• Audit logging for file views, downloads, and key workflow actions
• Defined retention and review processes for project records
• Secure reporting and export capabilities that support audit review without creating a culture of bulk data extraction
• Clear procedures for incident reporting and access revocation

6.3 Evidence is the real deliverable

In regulated environments, being secure is not enough. Teams must be able to demonstrate it. That means producing:

• Access history and audit logs
• Evidence of role-based permission configuration
• Records of workflow approvals and timestamps
• Documentation of how subcontractors were granted access and what they could access
• Proof of retention and governance practices
• A connected project platform can turn these evidence requests into routine reporting rather than a scramble during audits.

7. Implications for Construction Technology Selection

7.1 Why common construction software patterns struggle

Many platforms were designed for single-entity ownership, where one company “hosts” the project and others log in to collaborate. This model can work for productivity but often breaks down for regulated data handling because:

• It encourages downstream parties to export and re-upload data into their own tools
• It creates fractured audit trails across systems
• It makes it difficult to preserve a clear security boundary
• It increases the number of environments where sensitive data exists

7.2 What to look for in 2026

Owners and contractors should prioritize platforms that can support multi-stakeholder collaboration without forcing data duplication. Criteria include:

• True multi-organization permissioning and governance
• Audit logs that cover both files and form activity
• Configurable workflows with clear approvals and timestamps
• Reporting that supports oversight and compliance review
• A security posture appropriate for regulated environments when required, including FedRAMP-aligned environments for government use cases

For federal construction programs, it is increasingly difficult to justify systems that require teams to move sensitive data outside the authorized boundary to keep work moving.

8. Conclusions

As CMMC and DFARS requirements continue to shape defense construction in 2026, organizations should evaluate whether their current collaboration tools truly support secure, multi-stakeholder project delivery. Schedule a demo to see how a connected platform can help keep sensitive project data within a controlled environment while supporting real-world construction workflows.