What is NCODE? FAQs for Small Businesses 

NIST is stepping in to make CMMC compliance more affordable for small businesses. From what it is to how to apply, find the answers to industry FAQs.

Summary
NCODE is the Army’s new program helping small DoW contractors achieve affordable NIST 800‑171 and CMMC Level 2 compliance. It offers a secure environment, major cost savings, and access to Verified External Service Providers like Summit 7. Prepare your businesses by registering your interest in NCODE with the form below.

You’ve heard the exciting news that the Army’s Next-Gen Commercial Operations in Defended Enclaves (NCODE) is stepping in to make National Institute of Standards and Technology (NIST) SP 800-171 and Cybersecurity Maturity Model Certification (CMMC) Level 2 compliance affordable for small businesses. Let’s get into the most frequently asked questions about what NCODE entails and how it can help your business. 

What is NCODE? 

The NCODE marketplace is the Army’s solution to the compliance price barrier. It establishes a secure, foundational environment for pursuing CMMC and then pairs participating businesses with suitable Verified External Service Providers (VESPs), including Summit 7. The Army’s initial NCODE Solution budget is $49M over 5 years. The budget is expected to grow as other DOW organizations utilize NCODE. 

What does compliance cost with NCODE? 

Using the NCODE environment, participants save about $100K on infrastructure, MSP/MSSP services, licensing, and audit preparation and compliance support. However, participants are still responsible for paying for their CMMC Third-Party Assessor Organization (C3PAO) assessments. 

Who qualifies to join NCODE? 

NCODE serves Department of War (DoW) contractors with 2–10 employees and are pursuing CMMC compliance. working in their in-scope environments.  

Do I have to be an Army contractor to use NCODE? 

No, the NCODE program was launched by the Army, but availability has been extended across the entire DoW contracting landscape. 
 
That means NCODE is also available to Marine Corps, Navy, Air Force, Space Force, Major Defense Agencies, and National Guard contractors, providing relief for small businesses across the Defense Industrial Base (DIB) regardless of which DoW organization they are supporting.  

When can I join the NCODE program?  

The pilot program launching in May 2026 could reach as many as 1,000 small businesses moving to work in a CMMC-compliant environment. The initial window to participate in the NCODE pilot program is closed, but more slots may open during the before the launch of the full program.   

The main program is expected to launch within six months; Summit 7 is preparing to support up to 150,000 NCODE users during the first year of the program’s full launch.  

What can I do while I wait for NCODE? 

If you’re not in the pilot program, you’re in for a bit of a wait before you’re able to take advantage of NCODE, but that doesn’t mean you have to halt your preparations. 

Now is the perfect time to build internal knowledge and prepare your team for the non-technical requirements of CMMC Level 2.   

Preparing yourself as well as your company’s policies and procedures in areas like personnel security, hiring processes, business practices, and training will only improve your compliance timeline.  

A good place to begin is by visiting the Summit 7 Resources page and listening to our two regularly scheduled podcasts. 

Why should I select Summit 7 as my NCODE partner? 

Eligible companies will have the opportunity to select an NCODE vendor for the solution that best meets their needs. Some solutions propose using a shared environment for all aspects of the solution while others offer shared support and security models while establishing individual tenants for each company.  

Summit 7’s solution is designed to provide each company their own tenant while using shared infrastructure for support services, monitoring, and security aspects of each tenant, addressing a continued concern we hear within the industry about tenant and data ownership. Summit 7’s scalable NCODE solution is designed to grow with participating companies. We can rapidly deploy configured tenants to get environments operational and begin CMMC preparation as quickly as possible. 

Summit 7 is also the only Agreement for Online Services – Government (AOS-G) partner selected to participate in the NCODE Program.  We use our 8+ years of experience as a partner working with Microsoft 365 Government Community Cloud (GCC) High Licensing and Azure Government to provide high-end solutions while also ensuring that we don’t require a distributor or a licensing partner to obtain and deploy licenses. 

How do I apply for NCODE? 

To register your interest in the NCODE, fill out the form below.  

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