Phase 1 is Here: CMMC Compliance is Now a Mandatory Checkpoint
- clairekelley0
- 31 minutes ago
- 2 min read
The Department of War (DoW) has finalized the acquisition rule in Title 48 of the Code of Federal Regulations (CFR), cementing CMMC as an immediate contract requirement. This swift regulatory action, demonstrated by the Office of Information and Regulatory Affairs (OIRA) clearing the rule in just 34 days, underscores the government’s urgency regarding cybersecurity in the defense supply chain.
For organizations seeking to protect sensitive data, the timeframe is extremely tight: the longest expected delay between publication and the rule taking effect is only 60 days. Small businesses are now facing a reality check: CMMC is now a checkpoint. Applicable new DoW solicitations and contracts will include some level of CMMC requirement from November 10, 2025, forward.
This requirement moves compliance from simple guidance to an important contract requirement. The DoW has stated that Level 2 self-assessments (conducted internally, without mandatory involvement from CMMC Third-Party Assessment Organizations, or C3PAOs) may be included even in Phase 1.
Bids without current CMMC status or assessment scores posted in the Supplier Performance Risk System (SPRS) are likely to be deemed ineligible for DoW contracts, especially once the Title 48 acquisition rule becomes effective. Once the Title 48 acquisition rule is in force, if the required CMMC status is not present and current in SPRS, offers can be deemed ineligible regardless of their technical merit.
If you are expecting contract awards in the coming quarters, you should start acting now. For most organizations, the preparation, implementation, remediation, and assessment phases typically take 9 to 12 months. Organizations that align now will protect their contracts, strengthen their partnerships, and position their company as a trusted, secure partner to the DoW.
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