If your business is part of the Defense Industrial Base (DIB), big changes are on the horizon. Starting November 10, 2025, the Cybersecurity Maturity Model Certification (CMMC) Final Rule takes effect, officially embedding CMMC requirements into Department of Defense (DoD) contracts.
That means cybersecurity compliance is no longer optional guidance—it’s a contractual obligation. Whether you’re a prime contractor, subcontractor, or supplier handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), here’s what you need to know to stay compliant and competitive.
What Is the CMMC Final Rule?
The CMMC Final Rule, released on September 10, 2025, amends the Defense Federal Acquisition Regulation Supplement (DFARS) to enforce CMMC standards. The rule becomes enforceable 60 days later—on November 10, 2025.
Two new DFARS clauses matter most:
- DFARS 252.204-7021 – Requires contractors to meet specific CMMC levels.
- DFARS 252.204-7025 – Notifies offerors about possible CMMC requirements.
In simple terms: if your contract includes these clauses, your organization must have the right CMMC certification in place before award.
The Four-Phase CMMC Rollout
The DoD is phasing in CMMC to give contractors time to adapt. Here’s the timeline:
- Phase 1 (Nov 10, 2025): Some solicitations will include CMMC Level 1 or Level 2 (self-assessment). Use our CSATool for your self assessment. CSATool
DoD may also require third-party audits in select contracts. - Phase 2 (Nov 10, 2026): More Level 2 third-party certifications required. Level 3 begins in limited cases.
- Phase 3 (Nov 10, 2027): Level 2 third-party audits become standard. Level 3 expands.
- Phase 4 (Nov 10, 2028): Full implementation. Nearly all contracts handling FCI or CUI will require compliance.
Why November 10, 2025 Matters
While full enforcement won’t happen overnight, contracts issued after November 10, 2025 may already include CMMC clauses. That means your business must be ready—otherwise, you risk losing opportunities.
Key risks if you delay:
- Missed contract awards
- Assessment backlogs (limited third-party assessors)
- Supply chain disruptions if subcontractors aren’t compliant
- False Claims Act liability for misrepresenting compliance
How to Prepare for CMMC Compliance
Here’s a practical roadmap to get ready before the deadline:
1. Identify Your CMMC Level
- Level 1: For companies handling only FCI.
- Level 2: For companies handling CUI (based on NIST SP 800-171).
- Level 3: Rare, applies to higher-risk programs.
2. Audit Your Systems and Controls
- Map your current practices against CMMC requirements.
- Identify gaps and document them in a Plan of Action & Milestones (POA&M).
- Remember: some gaps won’t be allowed under the final rule.
3. Update SPRS Records
- Enter your CMMC Unique Identifier (UID) in the Supplier Performance Risk System (SPRS).
- Keep records up to date—contracting officers check this system before awards.
4. Prepare for Assessments
- For Level 2 and 3, schedule a Certified Third-Party Assessor Organization (C3PAO) or DoD audit.
- Book early—demand will be high once the rule takes effect.
5. Align Subcontractors
- Flow down CMMC requirements to all subcontractors handling FCI or CUI.
- Verify their compliance status before awarding subcontracts.
6. Strengthen Governance
- Assign a senior “affirming official” responsible for annual compliance attestation.
- Keep policies, incident response plans, and monitoring systems up to date.
Key Takeaway
The CMMC Final Rule is here, and November 10, 2025 marks the start of a new era in DoD contracting.
Organizations that take action now will gain a competitive edge, while those that wait risk falling behind. Begin with a readiness assessment, close security gaps, and engage your supply chain early.
