Introduction

Beginning November 10, 2025, the Department of War (née Department of Defense) will formally require that new solicitations and contracts include compliance with the Cybersecurity Maturity Model Certification (CMMC). For firms in the defense industrial base, that means compliance is no longer optional, but a condition of doing business with DoD and many of its primes. This guide demystifies the key steps, challenges, and strategies you need to get CMMC-ready, avoid lost contracts, and maintain competitive edge.

What Is Changing — A Snapshot

  • On November 10, 2025, the new DFARS rule (48 CFR) will go into effect, allowing DoD to include new CMMC clause language (DFARS 252.204‑7021 and 252.204‑7025) in contracts and solicitations.
  • Under the phased implementation, Phase 1 (Nov. 2025) requires self-assessment at Level 1, third-party assessment at Level 2, and government assessments for Level 3. (Side note: Although technically there are waivers for self-assessments for Level 2, they only serve a very narrow category of DoD contracts).
  • Full implementation—when every relevant contract must include CMMC compliance—will be reached by November 10, 2028.

What CMMC Levels Mean for You

  • Level 1 (Self-assessment): For contractors handling only Federal Contract Information (FCI). Requires basic cybersecurity hygiene, an annual self-assessment, and posting the results in SPRS (Supplier Performance Risk System).
  • Level 2 (Self or Third-Party Assessment): For contractors handling Controlled Unclassified Information (CUI). It includes the full suite of NIST SP 800‑171 controls (110 requirements). Almost all contracts require third-party assessment by a Certified Third-Party Assessor Organization (C3PAO).
  • Level 3 (Government Assessment): Reserved for the highest-risk CUI contracts. Adds controls from NIST SP 800-172 and requires assessments by DIBCAC (Defense Industrial Base Cybersecurity Assessment Center).

Implementation Roadmap

Here’s a practical roadmap to prepare for compliance:

  1. Contract & solicitation review
    Identify all current and anticipated contracts that process, store, or transmit FCI or CUI. Determine which CMMC level is likely required.
    Be alert: Contracting officers may include the new CMMC clause even in a contract that is awarded after Nov. 10, 2025.
  2. Gap analysis & readiness assessment
    Map your current cybersecurity posture (people, processes, technology) against the requirements of the target CMMC level. Identify gaps and risks, estimate remediation cost and timelines, and build your Plan of Action & Milestones (POA&M).
  3. Documentation building
    Create or update the System Security Plan (SSP), policies, control mappings, risk assessments, and POA&M. This documentation is critical for both self-assessments and third-party audits.
  4. Remediation & control implementation
    Execute the remediation plan. Typical tasks include deploying encryption, multi-factor authentication, logging and monitoring, endpoint protection, network segmentation, patching, access management, incident response, and continuous monitoring.
  5. Mock assessments / readiness testing
    Before your live assessment, run internal or third-party mock audits to surface deficiencies and improve your evidence collection and test procedures.
  6. Formal assessment / certification
    • For Level 1, you’ll perform the self-assessment and submit results (including artifacts) via SPRS.
    • For contracts requiring third-party assessments, engage a certified C3PAO. Schedule early — assessors will likely be booked.
    • For Level 3, you will be assessed by DIBCAC.
  7. Continuous compliance & recertification
    After certification, maintain control effectiveness, patching, monitoring, personnel training, change control, and revisit your POA&M. Certifications must remain current, and non‑compliance or drift can jeopardize contract status.

Key Risks and Pain Points

  • Audit capacity constraints
    As many contractors rush to certify, C3PAOs may become backlogged. It's prudent to engage early.
  • Scope creep and hidden dependencies
    Unanticipated systems or third-party integrations can expand the audit scope and remediation burden.
  • Artifacts and evidentiary rigor
    During a third-party review, auditors will demand evidentiary artifacts (logs, configurations, test results). Self-assessments don’t always require such rigor, but the audit will.
  • False Claims Act / compliance drift risk
    The rule expects that “there have been no changes in compliance since the contractor achieved the applicable CMMC status.” If compliance drifts after attestation, there may be FCA or contractual risk.
  • Flow-down pressure
    If you're a subcontractor, your prime may require verification of your status. Failure could cost you work.
  • Cost uncertainty
    As the DoD CMMC FAQ notes, “the cost of achieving CMMC compliance … depends on various factors, including … the complexity of the … network.”

Tips for Success

  • Don’t delay: the window to prepare is now.
  • Engage MSPs or compliance partners (like an MSP with CMMC specialization) early to assist with assessments, documentation, or remediation.
  • Reserve or pre-book assessor capacity early.
  • Break the project into phases or sprints to limit business disruption.
  • Focus early on establishing robust policies, incident response, logging, and governance.
  • Train staff and embed compliance awareness in daily operations.
  • Monitor policy updates, audit trends, and lessons learned from first movers.

Conclusion

CMMC is no longer a future possibility — it’s an imminent requirement that will reshape how defense contracting is done. For firms in the defense industrial base, getting ahead on assessment readiness, remediation, documentation, and audit booking is essential. Those who move methodically will maintain contract eligibility and reduce risk in a shifting regulatory environment.