Published June 5, 2026 by the Government.biz editorial team. Last reviewed on September 28, 2026. CMMC dates depend on rulemaking; verify specifics against official DoD sources.

Update — CMMC Phase 2 is suspended. On July 13, 2026 the Department of Defense suspended CMMC Phase 2, which was due to start November 10, 2026 and would have required C3PAO third-party Level 2 certification for applicable contracts involving CUI. It launched a CMMC Reform Task Force for a 60-day review. On September 3, 2026, a class deviation signed by the Defense Pricing, Contracting, and Acquisition Policy (DPCAP) office made the pause binding: contracting officers must remove Phase 2 third-party assessment requirements from active solicitations and existing contracts. Still in force: Level 1 and Level 2 self-assessments, DFARS 252.204-7012 / 7019 / 7020, NIST SP 800-171 Rev. 2, SPRS scores, and annual affirmations. The task force report went to the DoD CIO in September; as of late September 2026 its recommendations had not been made public.

Few topics in defense contracting have generated more confusion than CMMC's timeline. Headlines have promised "CMMC required next year" for several years running. The reality in 2026 is more nuanced — and more manageable — than the headlines suggest: CMMC is real, the rules are final, and the requirement is being phased in over several years rather than switched on all at once. Phase 1 began November 10, 2025; Phase 2, the third-party certification step, was suspended in July 2026 before it started. Here's where things actually stand.

The two rules that matter

CMMC runs on two separate regulations, and conflating them is the source of most confusion:

The practical takeaway: CMMC becomes binding on you contract by contract, when a solicitation includes the clause — not on a single nationwide "go-live" date. The phase-in determines which contracts get it first.

The four-phase rollout

Rather than requiring every contractor to be certified on day one, the DoD designed a staged rollout that ramps up over roughly three years:

PhaseWhat it introduces
Phase 1 (began Nov. 10, 2025)CMMC Level 1 and Level 2 self-assessment requirements begin appearing in applicable solicitations. In effect.
Phase 2 (was Nov. 10, 2026)Level 2 third-party (C3PAO) certification requirements added for applicable contracts. Suspended July 13, 2026; a September 3, 2026 class deviation requires these requirements to be removed from solicitations and contracts.
Phase 3 (scheduled Nov. 10, 2027)Level 3 requirements are introduced for the highest-priority programs. Timing depends on the outcome of the reform review.
Phase 4 (scheduled Nov. 10, 2028)Full implementation — CMMC requirements apply across all applicable DoD solicitations and contracts. Timing depends on the outcome of the reform review.

Each phase was meant to build on the last, giving the assessor ecosystem time to scale. The DoD cited compliance costs, limited third-party assessment capacity, and small businesses leaving the defense industrial base when it paused Phase 2. Reversing the pause now takes regulatory action rather than a memo, so treat any date for third-party certification with caution until the DoD publishes the reform task force's outcome.

The three levels in brief

Level 1 — Foundational

17 basic practices protecting Federal Contract Information (FCI). Met by an annual self-assessment; no external assessor required.

Level 2 — Advanced

The 110 controls of NIST SP 800-171, protecting Controlled Unclassified Information (CUI). Met by self-assessment for some contracts and, under the original rule, a C3PAO assessment every three years for others. With Phase 2 suspended, C3PAO certification is not currently required as a condition of award. This is where most affected contractors land.

Level 3 — Expert

Adds controls from NIST SP 800-172 for advanced-threat protection. Government-assessed and reserved for the highest-priority programs.

For the full breakdown of practices, costs, and the assessment process, see our CMMC certification guide.

What to do now — even before it's in your contracts

The contractors who will struggle are the ones who wait for CMMC to appear in a solicitation and then scramble. Getting to Level 2 from a standing start can take many months. Practical steps to take today:

  1. Determine whether you handle FCI, CUI, or neither. This tells you whether you're looking at Level 1, Level 2, or no requirement. See CUI handling.
  2. Do a NIST 800-171 gap assessment. If you handle CUI, score yourself against the 110 controls and identify the gaps.
  3. Keep your self-assessment score current in SPRS. A current Supplier Performance Risk System score has been expected under existing DFARS clause 252.204-7012 / 7019 well ahead of CMMC, and it's the baseline assessors will look at.
  4. Build your System Security Plan (SSP) and POA&M. These documents are foundational to any Level 2 assessment.
  5. Flow requirements to subcontractors. If your subs touch CUI, they'll need their own appropriate CMMC level — start that conversation early.
Bottom line: the Phase 2 suspension removes the third-party certification deadline, not the underlying obligation. If you handle CUI you must still implement NIST SP 800-171, keep an accurate SPRS score, and affirm compliance, and inaccurate self-assessments still carry False Claims Act risk. Keep working on Level 2 readiness so you are not scrambling if third-party assessments return.

Frequently asked questions

Is CMMC Phase 2 suspended?

Yes. On July 13, 2026 the DoD suspended CMMC Phase 2, which was scheduled to begin November 10, 2026 and would have required C3PAO third-party Level 2 certification for applicable contracts involving CUI. On September 3, 2026 a DoD class deviation made the suspension binding by directing contracting officers to remove Phase 2 third-party assessment requirements from active solicitations and existing contracts. A CMMC Reform Task Force conducted a 60-day review; as of late September 2026 its recommendations had not been made public.

Is CMMC required yet in 2026?

Partly. Phase 1 began November 10, 2025, so CMMC Level 1 and Level 2 self-assessment requirements can appear in DoD solicitations. Phase 2 third-party certification is suspended. DFARS 252.204-7012 and NIST SP 800-171 Rev. 2 compliance, SPRS scores, and annual affirmations still apply. Whether a specific contract requires CMMC, and at what level, depends on the solicitation — always check it.

What CMMC level do most contractors need?

Most contractors handling CUI need Level 2 (the 110 NIST 800-171 controls). Those handling only FCI generally need Level 1 (annual self-assessment). Level 3 applies to a small set of the highest-priority programs.

Can I still self-assess for Level 2?

Yes. With Phase 2 suspended, DoD is not requiring C3PAO certification as a condition of award, so Level 2 requirements in contracts are met by self-assessment and annual affirmation. A C3PAO assessment is now voluntary, though some firms still pursue one for competitive positioning. Level 1 is always self-assessed; Level 3 is government-assessed.

Related reading

Authoritative sources: DoD CIO — CMMC and 32 CFR Part 170; Phase 2 suspension: DoD Office of Small Business Programs and Nextgov/FCW on the September 3 class deviation. This page is general information, not legal or cybersecurity advice.