CMMC Phase 1 Implementation (Nov 10, 2025 – Nov 9, 2026) to focus primarily on CMMC Level 1 and Level 2 self-assessments.
Cybersecurity Maturity Model Certification (CMMC) is a framework residing within IT security. It was developed in cooperation with Carnegie-Mellon (University), Johns Hopkins (University), the Defense Industry Base (DIB), and the US Department of Defense (DoD). CMMC initially launched in a version 1.0, and has recently been replaced by, what is to be an expected final version (2.0)
Within CMMC Three Different Compliance Levels Exist.
Companies seeking eligibility for future DoD tenders will be met with a requirement of being CMMC Level 2.0 compliant. This applies not only to Primes but also to all subcontractors down the supply chain (flow down). Existing subcontractors will be, if not already required to be compliant with NIST 800-171, the same requirements on contract extensions.
The final step of the implementation of CMMC is calculating the score of the implemented security elements. This score is to be registered with the Supplier Performance Risk System (SPRS) and is a requirement. DoD has access to all companies registering their score and is expected to use this when evaluating tenders.
The DOW defines the required CMMC level on each specific tender in order to be contract eligible. Contracts where CUI (Controlled Unclassified Information) is being processed, will at minimum require a level 2, whereas contracts without CUI may only be required to be at level 1. It is worth noting that communicating FCI (Federal Contract Information), requires a level 1 certification. Companies only dealing with COTS (Commercial-Off-The-Shelf) are not expected to be CMMC compliant.
CMMC 2.0 is based on the NIST 800-171 framework, which originates from the protection of CUI (Controlled Unclassified Information). Companies already compliant with NIST 800-171 (DFARS 252.204-7012, 7019 & 7020) will be on fast-track with CMMC certification. With a full 110/110 implemented elements, the final path to CMMC certification is estimated to be 3-6 months. If no elements or experience with NIST 800-171 exist, implementation will soon take up to a year, in order top be level 2 compliant.
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