ITAR Registration Code:
M49438 / Cage Code: 94U86

The Smaller War Plants Commission: What Small Defense Manufacturers Need to Know About CMMC, CUI, and the New Funding Push

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On August 25, 2026, the U.S. Small Business Administration (SBA) and the Department of War announced the creation of the Smaller War Plants Commission, a new initiative designed to strengthen the domestic Defense Industrial Base (DIB) by expanding support for small U.S. manufacturers.

Despite its name, the Commission isn’t limited to companies that make weapons in the traditional sense. It’s aimed broadly at small businesses producing the products, parts, materials, and technology that national defense depends on, everything from castings and forgings to microelectronics and drones. For a country that has spent decades consolidating defense manufacturing into a small number of large primes, the announcement signals a deliberate policy shift back toward a broader, more distributed industrial base.

Why This Is Happening Now

The name “Smaller War Plants Commission” is a deliberate callback to the World War II-era Smaller War Plants Corporation, which was created to make sure small manufacturers, not just large industrial giants, had a role in wartime production. The revival of that model reflects growing concern in Washington about supply chain fragility, dependence on foreign sourcing for critical components, and the shrinking number of domestic manufacturers capable of scaling quickly for defense needs.

Rather than creating an entirely new bureaucracy, the Commission is structured as a joint SBA and Department of War effort, pairing the SBA’s small business lending and support tools with the Department of War’s acquisition priorities and supply chain visibility. That pairing matters: it means financial support and defense contracting access are meant to move together, rather than as two separate, disconnected programs a company has to navigate independently.

What the Commission Is Meant to Do

According to the SBA’s announcement, the initiative is designed to:

  • Improve access to loans and investment for defense-critical small businesses
  • Offer loan guarantees as high as 90% for eligible manufacturers
  • Help finance equipment, facilities, inventory, acquisitions, and production expansion
  • Connect small businesses with defense contracting opportunities
  • Identify gaps in the domestic defense supply chain
  • Cut regulatory bottlenecks that keep small manufacturers from scaling
  • Build a manufacturing capacity inventory through the new Civil Reserve Manufacturing Network

Taken together, these components suggest something bigger than a typical grant program. The 90% loan guarantee figure is notable; it’s a substantially more generous guarantee than most SBA lending programs offer, and it signals that the government wants to remove financing as a barrier for manufacturers who are otherwise qualified but capital-constrained.

Priority Industries

The Commission has flagged several sectors as strategic priorities:

  • Munitions and components
  • Drones
  • Microelectronics
  • Critical Minerals
  • Shipbuilding and repair
  • Sensors and batteries
  • Castings and forgings
  • Defense textiles

These are the sectors where the government has identified the most acute domestic capacity gaps, often because production shifted overseas over the past several decades, or because these components are choke points in larger weapons systems and platforms. If your company operates anywhere on this list, this is a program worth watching closely.

It’s also worth noting what this list implies about eligibility. Many companies in these sectors don’t think of themselves as “defense contractors” in the traditional sense. A battery manufacturer or a textile producer may supply commercial customers first and defense customers only indirectly, through a tier-two or tier-three subcontract. The Commission’s language suggests it’s designed to capture exactly these kinds of companies, not just firms that already hold prime defense contracts.

A Closer Look at the Civil Reserve Manufacturing Network

One of the more novel elements of the announcement is the Civil Reserve Manufacturing Network, a planned inventory of domestic manufacturing capacity that the government could draw on in a surge or crisis scenario. The concept echoes the long-standing Civil Reserve Air Fleet program, which allows the Department of War to call on commercial airlines during a national emergency.

For small manufacturers, being cataloged in this network could become a meaningful credential in its own right: a signal to primes and contracting officers that a facility has been vetted and is ready to scale production quickly. But it also implies a layer of due diligence. Facilities that want to be part of this network will likely need to demonstrate operational readiness, including the security posture of the systems that manage their production, inventory, and design data.

What This Isn’t, Yet

It’s worth being clear-eyed about where things stand. The Smaller War Plants Commission has been established, but the SBA has not yet published application procedures, priority NAICS codes, formal qualification rules, or funding timelines. This is not a new CMMC requirement, a grant program you can apply to today, or an automatic funding source for every company in the Defense Industrial Base.

Right now, it’s best understood as a major policy direction, a signal of where federal investment is heading, with the operational details still being worked out. Companies should treat the coming months as a planning window rather than an application window.

The Real Opportunity: Readiness

Here’s the part that matters most for companies supporting the defense supply chain: money and opportunity without security is a liability, not an advantage.

If the Commission succeeds in its goals, small manufacturers across these priority sectors will start winning more capital, more contracts, and more direct defense work. But new defense work comes with new obligations: protecting Controlled Unclassified Information (CUI), meeting Cybersecurity Maturity Model Certification (CMMC) requirements, complying with ITAR where applicable, and operating in a demonstrably secure IT environment.

In other words, the businesses best positioned to benefit from this initiative won’t just be the ones with the best manufacturing capacity. They’ll be the ones that can prove they’re secure enough to be trusted with the work. A manufacturer that expands production but cannot meet the CMMC Status required by a future solicitation may find itself unable to compete for or receive that contract.

The government is preparing to invest more heavily in small defense manufacturers. But before these businesses can fully capitalize on new defense opportunities, they need to be ready to protect CUI, meet CMMC requirements, and operate in a compliant, secure environment.

Why CMMC, CUI, and ITAR Compliance Matter More Than Ever

For manufacturers who have historically operated as subcontractors several tiers removed from a prime contractor, defense compliance requirements can feel abstract until a contract, teaming agreement, or funding opportunity suddenly requires proof of them. As the Commission connects more small manufacturers directly with defense contracting opportunities, more companies will find themselves handling Controlled Unclassified Information for the first time, which may bring them within the scope of CMMC Level 2 requirements when those requirements are included in the applicable solicitation or contract.

This isn’t a hypothetical compliance exercise. When a solicitation specifies a required CMMC Status, cybersecurity readiness can become a gating factor for contract award. For solicitations requiring a particular CMMC Level 2 Status, failure to achieve and maintain that required status can affect eligibility for award. As funding and contracting activity accelerates under this initiative, the manufacturers who have already closed their compliance gaps will move faster than those scrambling to catch up after the fact.

Preparation isn’t something that can be compressed into a few weeks once a contract or funding opportunity appears. A genuine CMMC Level 2 readiness effort, covering system boundaries, the 110 security requirements of NIST SP 800-171 Revision 2, documentation, and applicable assessment requirements, can take significant time to complete well, and manufacturers who wait until an opportunity is already on the table give themselves little room to do that work properly.

Don’t Forget the Shop Floor: OT and IIoT Are Part of the Scoping Conversation

For manufacturers, CMMC readiness isn’t just an office-IT exercise. CMMC’s Level 2 Scoping Guide identifies several categories of assets that come into play, including CUI Assets, Security Protection Assets, Contractor Risk Managed Assets, and Specialized Assets. That last category is especially relevant on a shop floor: it explicitly covers things like Internet of Things (IoT) and Industrial Internet of Things (IIoT) devices, Operational Technology (OT), Government Furnished Equipment, Restricted Information Systems, and Test Equipment.

In practice, that means a company evaluating its CMMC scope should be looking beyond laptops and servers to production equipment that may fall within these asset categories, potentially including CNC machines, programmable logic controllers, networked sensors, and other operational technology that might touch CUI or sit on a network segment connected to systems that do. Getting this scoping right early, before an assessment or a new contract requirement forces the issue, is one of the more manufacturing-specific pieces of CMMC readiness that’s easy to overlook.

What Small Manufacturers Should Do Now

Even with the specifics still emerging, there are concrete steps manufacturers in these priority sectors can take today:

  1. Assess your current cybersecurity posture against CMMC Level 2 requirements, especially if you handle or expect to handle CUI.
  2. Map your compliance gaps before funding or contract opportunities arrive, not after.
  3. Talk to a partner who understands both manufacturing operations and defense compliance, so security doesn’t become the bottleneck that slows down growth.
  4. Watch for SBA guidance on application procedures, NAICS eligibility, and funding timelines as the Commission’s programs take shape.
  5. Get your supply chain documentation in order, since gap analysis under this initiative will likely rely on visibility into subcontractor and supplier relationships.
  6. Build a relationship with your IT and compliance provider now, rather than treating them as a vendor you call only once a deadline is looming.

What to Expect Next

Programs of this scope typically roll out in phases: initial framework and leadership appointments, followed by published eligibility criteria and NAICS code guidance, then formal application windows for loan guarantees and other financial tools. Manufacturers may have a window between this announcement and the launch of functioning application processes. That window is an opportunity to address compliance readiness, since assessments, remediation, and documentation take time, and they’re far easier to complete before a deadline is on the calendar than after.

Frequently Asked Questions

Does the Smaller War Plants Commission create a new CMMC requirement?
No. The Commission is a financing, contracting access, and supply chain initiative. CMMC requirements come from individual solicitations and contracts, not from the Commission itself. But manufacturers that win more defense work through the Commission’s programs will increasingly encounter contracts that require a specific CMMC Level 2 Status.

How do manufacturers know which CMMC requirements apply to them?
The applicable CMMC Status is determined by the specific solicitation or contract and depends on the information the manufacturer will process, store, or transmit. Manufacturers should review contract language carefully or work with a compliance partner, rather than assume a single standard requirement applies to every defense contract.

What happens if a manufacturer doesn’t meet the required CMMC Status?
For solicitations that specify a particular CMMC Level 2 Status, failing to achieve and maintain that status can affect eligibility for award. The exact impact depends on the terms of the specific solicitation or contract.

Does CMMC only apply to office IT systems?
No. CMMC’s scoping guidance covers a range of asset categories, and for manufacturers, that can include Specialized Assets such as IoT and IIoT devices, Operational Technology, Government Furnished Equipment, Restricted Information Systems, and Test Equipment. A manufacturer’s scoping exercise should account for shop-floor equipment, not just office computers and servers.

Bottom Line

The Smaller War Plants Commission represents a significant policy shift toward strengthening America’s small manufacturers in defense-critical industries. The funding, contracting connections, and supply chain support it promises could be substantial, but only for businesses that are prepared to meet the security and compliance bar that comes with defense work.

The companies that start building CMMC readiness now, before the funding programs are fully live, will be positioned to move fast when opportunities arise.

Source: Official SBA Announcement, August 25, 2026

Schedule a free consultation with the Brea Networks team to review your current environment, identify compliance risks, and understand what steps are required to move forward. A short conversation can help you avoid costly mistakes and focus on what matters for contract eligibility and security.

About Brea Networks

Brea Networks is a cybersecurity and compliance-focused IT partner dedicated to supporting Defense Industrial Base (DIB) contractors. We help organizations understand and implement the security requirements outlined in FAR 52.204-21, DFARS 252.204-7012, and the CMMC framework from Level 1 self-assessments to Level 2 and Level 3 readiness. Our team works alongside contractors to strengthen system security, define assessment scope, prepare documentation such as System Security Plans (SSPs) and POA&Ms, and build sustainable cybersecurity programs that protect FCI and CUI. Whether you are preparing for a self-assessment or simply improving your security posture. Brea Networks provides practical guidance and technical expertise to help you move forward with confidence.

Brea Networks, LLC
471 W Lambert Rd Ste 105
Brea, CA 92821

https://www.cmmccompliance.us
https://www.breanetworks.com

Telephone: 714-592-0063

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