
As of early 2025, the CMMC program has officially moved from "planning" to active implementation. The DoD finalized the 32 CFR rule in late 2024, legally establishing the program, and requirements are now starting to appear in new contracts.The DoD is utilizing a four-phase rollout over the next three years to manage the transition:
Phase 1 (Current): CMMC self-assessments (Level 1 or Level 2) and senior official affirmation are being required in some solicitations as a condition of award.
Phase 2 (Starting mid-2025): The DoD can begin requiring C3PAO (Third-Party) Certification for Level 2 (CUI handling) in new contracts. This is when the bottleneck for assessments is expected to begin.
Phase 3 (2026): CMMC Level 2 Certification will be required for all applicable contract awards, including renewals. The first assessments for CMMC Level 3 (highest level) may also begin.
Phase 4 (2027-2028): Full implementation is complete. CMMC requirements will be included in all applicable DoD solicitations, including existing contract renewals, without exception.Most current DoD contracts already include the DFARS 252.204-7012 clause, which means regardless of the CMMC phase, you are already required to have a System Security Plan (SSP), a Plan of Action & Milestones (POA&M), and an up-to-date SPRS Score.
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