CMMC Is Not Waiting for You

The Cybersecurity Maturity Model Certification (CMMC) program does not arrive with a single deadline. It arrives when the clause shows up in your contract. When that happens, there is no grace period and no workaround.

DoD plans to roll CMMC into solicitations gradually, starting as early as 2025. During this early phase, Level 1 will require self-assessments and annual affirmations in SPRS. Some Level 2 work may also allow self-assessment, but only where the program office permits it. These requirements apply immediately to new awards that include the CMMC clause.

By 2026, many contracts involving Controlled Unclassified Information (CUI) are expected to require CMMC Level 2 at award. For a growing portion of that work, third-party assessments by a C3PAO will be mandatory. This is where most contractors will feel real pressure. Assessment capacity is limited, scheduling delays are common, and certification timelines do not pause contract awards.

Between 2026 and 2027, the assessment bottleneck becomes the risk. Even organizations that are technically compliant may miss bids simply because certification could not be completed in time.

In the later years, Level 3 requirements apply to a small set of critical national security programs, and CMMC becomes standard across most applicable DoD contracts. At that point, certification is no longer a differentiator. It is table stakes.

Why this matters:
If a solicitation requires CMMC and you are not certified, you cannot bid. There is no appeal and no extension. The loss often looks invisible, not dramatic. You simply stop qualifying.

What to do now:
Run a NIST SP 800-171 gap analysis, document your System Security Plan, remediate deficiencies, and plan for assessment early. Waiting for a solicitation is already too late.

CMMC does not lock you out all at once. It locks you out contract by contract.