For MSPs supporting defense contractors, federal agencies, and cloud service providers, 2026 marks a turning point when most regulatory bodies expect architecture, compliance, and service delivery to align.
This is made even more readily apparent with changes in federal requirements. The DoD’s phased rollout of CMMC and FedRAMP 20x are clear signal that the government expects MSPs to focus on modern, risk-focused security.
This shift to identity-based security has had major implications for compliance. Frameworks like FedRAMP, CMMC, and NIST 800-series controls all rely on strong identity practices. Yet areas like Identity Assurance remain a consistent challenge.
Many organizations assume that if a user can log in with MFA, their identity is secure. In reality, authentication only proves that someone possesses a credential. Identity assurance determines whether the system actually knows who that person is.
When the Department of Defense released CMMC FAQs Revision 2.1 in November 2025, the update appeared modest on the surface. Four new questions were added without changing the CMMC model or the underlying regulatory framework in 32 CFR Part 170. For organizations already fatigued by years of CMMC evolution, it would be easy to dismiss these
Importantly, each of these four additions resolves an ambiguity that many contractors had been relying on to narrow the scope, defer remediation, or justify architectural shortcuts. Collectively, they close several loopholes that organizations assumed would remain open until formal enforcement began.
This article covers each of these new FAQs, the assumptions they invalidate, and how organizations should adjust their compliance strategies accordingly.