Comment on FR Doc # 2026-12559

Re: FAR Case 2026-001, Revolutionary Federal Acquisition Regulation Overhaul (Controlled Unclassified Information), 91 FR 37550 (June 23, 2026). Submitted by: Adams Cloud Cybersecurity LLC, a Service-Disabled Veteran-Owned Small Business (SDVOSB). UEI LKEZE1QZGLG3, CAGE 1ZPT9, NAICS 541512. Point of contact: Thabiti Adams, Principal, CISSP, CCSP. We appreciate the opportunity to comment on the proposed rule revising Controlled Unclassified Information (CUI) safeguarding and cyber-incident reporting. We are a Service-Disabled Veteran-Owned Small Business that helps small and medium contractors reach and sustain compliance with NIST SP 800-171 and CMMC. Our comments come from direct field work with the smallest firms in the industrial base, and they complement our July 15, 2026 response to CMMC Reform RFI 26-P-1023. We support the rule's goals of protecting federal information and harmonizing incident reporting. We ask the Council to weigh four small-business impacts. The move from 800-171 Rev 2 to Rev 3 should come with transition support, not just a deadline. The shift is reasonable on the merits, but for a firm with fewer than ten people it means re-deriving the System Security Plan against a re-baselined standard, defining a new set of organization-defined parameters, and standing up a Supply Chain Risk Management program that has no Rev 2 equivalent. We recommend: (a) a clearly stated effective date and grandfathering window so a firm mid-assessment on Rev 2 is not stranded; (b) a government-published Rev 2 to Rev 3 crosswalk and updated free self-assessment tooling; and (c) recognition that evidence built to the Rev 3 objective set satisfies Rev 2, so firms are not penalized for building forward. Harmonize the 72-hour reporting timeline, do not multiply it. Aligning the incident-reporting window with existing frameworks is welcome. The burden small firms actually feel is not the 72 hours; it is reporting the same incident into multiple portals under multiple definitions. We recommend a single reporting pathway and one consistent definition of a reportable CUI incident across DFARS 252.204-7012 and this rule, so a small contractor reports once, not three times. Recognize commercial capabilities and managed services as evidence. Small firms already pay for managed identity with enforced multifactor authentication, government-community cloud, managed detection and response, and continuous vulnerability scanning. Today those investments earn no formal credit, so the firm pays once for the tool and again to prove it exists. We recommend the rule permit a firm to map an accredited commercial capability or a managed security service provider attestation directly to the corresponding requirements and accept that mapping as evidence. Keep the standard, scale the burden, and stabilize the numbering. The NIST 800-171 requirements remain the right baseline; the cost that drives small firms out is the assessment and documentation machinery layered on top, and the recurring cost of relearning renumbered clauses. We recommend a defined core set of high-value controls as a fast, complete on-ramp for self-attesting small firms, a supported small-business CUI enclave reference architecture to shrink scope, and a single, stable, plain-language contractor guide maintained in one place. Summary: Keep the standard. Scale the assessment and the paperwork. A rule that pairs the Rev 3 update with real transition support, a single harmonized reporting pathway, recognition of existing commercial security, and a stable, plain-language guide would protect federal information and improve resilience while keeping the smallest capable firms in the industrial base eligible to compete. Respectfully submitted, Thabiti Adams, Principal, Adams Cloud Cybersecurity LLC. CISSP, CCSP. SDVOSB. California DVBE 2051644. UEI LKEZE1QZGLG3. CAGE 1ZPT9. NAICS 541512.