Subnet345

Industries · Military & Defense · Record Substrate

Your AI agents are acting on controlled data an assessor will ask you to account for.

Defense contractors are moving agentic systems into production against CUI. CMMC and NIST 800-171 expect an attributable record of that access. Built by a veteran-led team, the substrate produces it, inside your own boundary, designed to run air-gapped. Until the model runs inside your boundary, the model path leaves it: that path is not air-gapped and is not for CUI or classified information.

CMMC 2.0
Contractors handling CUI must meet Level 2 safeguards (NIST 800-171); assessments are phasing into DoD solicitations. The controls assume an attributable, reviewable record of access to CUI.
DoD IL4 / IL5
Impact Levels govern CUI and higher-sensitivity data in cloud and customer-installed DoD environments. Agents that act on that data inherit the logging and attribution burden.
NIST 800-171 / 800-53
The control baselines behind CUI protection: audit and accountability (AU) and access control (AC) families that presuppose a trail an assessor can interrogate.

§ 01 Why now

Can you account for what your agents did with CUI?

2026 to 2027

Enforcement. The assessor asks.

The NDAA for FY2026 directs the Department of Defense to build an AI security framework. The obligation to account for what an agent did against controlled data arrives before the rule that names it.

The assessment question

If a DoD assessor asked you to reconstruct every action your agents took against controlled data last quarter, what would you show them?

§ 02 Use cases

Where the substrate lands first.

Contract work on CUI

Agents that draft, review, and reconcile against controlled data, with access attributed and reviewable.

Restricted and disconnected environments

Coordination, policy, and the record run inside your boundary. The substrate is designed to run air-gapped: once installed, the substrate needs no route out, so it fits environments that cannot reach the open internet. An offline install path is on the roadmap. The substrate is designed to run air-gapped; the models are not yet. Sovereign-model deployment inside the perimeter, where even the model behind the agent runs without outbound traffic, is on the roadmap through our model-training pipeline. In a fully self-hosted deployment, with the model on your GPUs and the record and telemetry on your own infrastructure, your data stays in your perimeter. That is a configuration you set, not the shipped default.

The defense supply chain

Prime and subcontractor accountability across handoffs: which agent acted, under whose authority, against which controlled resource.

§ 03 Against the frameworks

Measured against what the assessment expects.

CMMC, the NIST 800-171 and 800-53 baselines, and the DoD Impact Levels point toward a common expectation: access to controlled data must be attributed, reviewable, and kept inside a controlled boundary.

This material does not constitute legal or regulatory advice, and Subnet345 holds no CMMC certification or Impact Level authorization. Assess your obligations with your assessor.

ExpectationAttributable access to controlled data
FrameworkCMMC · 800-171
WithoutNo access trail
With Subnet345Access attributed
ExpectationOperation inside a restricted boundary
FrameworkIL4 / IL5
WithoutCloud-dependent
With Subnet345In-perimeter
ExpectationReviewable agent action history
FrameworkNIST 800-53 AU
WithoutReconstructed later
With Subnet345Attributed, tamper-evident chain

Sources: CMMC 2.0 (DoD CIO); NIST SP 800-171 (CMMC and DFARS enforce Rev 2 today; Rev 3 is the current NIST publication) and SP 800-53 (Rev 5); DoD Impact Levels (DoD Cloud SRG). Regulatory mapping reviewed: August 2026. Informational, not legal advice.

The question we help you answer

Can you show what your agents did with controlled data, and under whose authority?