Passwordless authentication is a potential lynchpin for organizations struggling with identity as their security perimeter. While neither FedRAMP nor CMMC explicitly mandates passwordless technologies, both frameworks set requirements and outcomes that passwordless authentication can meet.

For organizations operating in regulated environments, especially those handling government data or CUI, passwordless authentication is no longer an emerging trend. It is rapidly becoming the most defensible approach to meeting modern compliance expectations.

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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.

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As 2026 approaches, the mix of tighter regulations and sharper customer expectations is pushing operational security to the forefront. The core principles of cybersecurity haven’t changed much, but the way we put them into practice absolutely has. This guide is meant for SaaS teams that want to strengthen their security in a practical, sustainable way, not just get through another audit.

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