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.
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.
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.