The CMMC Countdown is Over: What Every DoD Contractor Needs to Know NOW

As CMMC Assessors, we have been closely watching the Cybersecurity Maturity Model Certification (CMMC) journey, offering guidance, dispelling myths, and preparing the defense industrial base for the inevitable. Today, we bring you news of monumental significance that confirms what we have stressed for years: CMMC is no longer a distant threat; it is an immediate reality for your DoD contracts. 

The big reveal, the one we have all been anticipating, happened on July 22nd, 2025: The Department of Defense (DoD) officially transmitted the final CMMC rule to the Office of Information and Regulatory Affairs (OIRA) for its final regulatory review. This is the second-to-last milestone before the official CMMC phased rollout begins, and CMMC requirements start showing up in your contracts. 

The importance of this recent transmission cannot be overstated: the 48 CFR rule takes the established policy from 32 CFR and makes it contractually enforceable. Do not expect any changes to existing CMMC requirements or guidance; this rule simply enables the DoD to include language in contract solicitations stating that to be awarded work, you will need CMMC Level 1, 2, or 3 certifications. 

Based on our analysis, we anticipate CMMC requirements will begin appearing in DoD contracts and solicitations as early as October 2025 and no later than February 2026. The most likely timeframe is Q4 of 2025. CMMC is a major priority for the DoD. The Secretary of Defense signed a memo on July 18th, emphasizing CMMC as a critical part of their cybersecurity assurance strategy. This means that from October 2025 onward, CMMC requirements will begin appearing in DoD solicitations as part of the phased rollout. 

Even the most conservative, longest timeline (120 days for OIRA, 3 weeks for publication, plus a hypothetical 60-day delay if the rule's status were to change) still puts the effective date no later than February 2026. So, whether it is Halloween or the Super Bowl, the window is narrow, and the imperative to act is clear. 

Time is Up: Critical Takeaways for Defense Contractors 

From an assessor's perspective, our message to you is unequivocal: the hourglass is almost out of sand. 

There is a significant misconception that CMMC Level 2 C3PAO certification will not be required until Phase 2 (one year after the 48 CFR rule takes effect). This is false. The DoD has complete discretion to require C3PAO assessments in Phase 1. Moreover, a January DoD acquisition memo guided contracting officers that for contracts involving data types in the Defense Category of the NIST CUI Registry (like Controlled Technical Information, Naval Nuclear Propulsion Information, DoD Critical Safety Information – the data most defense contractors handle), the minimum requirement is CMMC Level 2 C3PAO certification. Do not wait; do not assume a self-assessment will suffice if you handle CUI. 

Waivers for CMMC requirements are incredibly rare and exist only for entire classes of acquisitions, determined before solicitations are released. By the time you see a solicitation with a CMMC requirement, it has already been determined that a waiver is not applicable. If you are a subcontractor, this goes double for you. 

Many companies require 9 to 12 months to go through the full CMMC implementation, assessment, and certification process. Factors like budgets, internal approvals, and planning contribute to this timeline. If you wait until you see CMMC requirements in solicitations, you have, quite simply, waited too long. 

If you expect solicitations in summer 2026 and your customer takes three months to award, you need your CMMC certification in hand three months after that solicitation comes out. For many, that means starting now. 

If you are planning on taking an award of a contract in the next 12 months, and you are not already closing in on your certification or have it in hand, you may have a genuine problem on your hands. 

Your Next Move 

This is not a drill. The CMMC train is not just approaching the station; it has received its final clearance and is preparing for departure, with CMMC requirements as its mandatory ticket. 

The time for speculation is over. The time for action is now. 

Schedule your free consultation today. 

About AXIOTROP, LLC:  

Ready to start your CMMC journey? Begin by identifying your cybersecurity gaps and building a tailored remediation plan and budget. AXIOTROP’s mission is to make cybersecurity accessible, attainable, and sustainable for small and medium-sized businesses, so they remain competitive and poised for growth. We simplify cybersecurity by working closely with businesses to right-size their program for their needs, resulting in client retention, business expansion, and reduced risk.