CMMC Phase 2 Is 10 Months Away: A No-BS Prep Timeline for Level 2 Third-Party Certification

If you handle (or plan to handle) Controlled Unclassified Information (CUI) on DoW contracts, Phase 2 starts November 10, 2026. That is when the DoW begins requiring Level 2 certification through a Certified Third-Party Assessment Organization (C3PAO) as a condition of award for applicable new contracts.

No more self-attestation for Level 2 on those deals. You need an independent assessment against the 110 NIST SP 800-171 controls, along with proper scoping, evidence, System Security Plan (SSP), Plans of Action and Milestones (POA&Ms), and executive affirmation.

The timeline is real, but the bottlenecks are too. C3PAO capacity remains limited (fewer than 100 authorized assessors against demand from tens of thousands of organizations), and early 2026 reports show lead times stretching 3 to 12 months or more. Remediation timelines vary a lot: 6 months if your posture is already strong, 12 to 18 months or longer if gaps are wide. Budgets? Most small to mid-size organizations should plan for $75,000 to $300,000 or more total, with the assessment itself often $30,000 to $75,000. Those are realistic ranges pulled from industry patterns, not lowball DoW estimates that ignore remediation and internal effort.

Here is a grounded, phased timeline to reach certification without scrambling at the end.

Phase 0: Right Now (January to February 2026) – Scope and Gap Honestly

Do not skip this step. Poor scoping causes more assessment failures than weak technical controls.

Map your CUI environment in detail: Where does it reside? Cloud services? On-premises systems? Subcontractor transfers? Remote access? Get this wrong, and you either assess too much (wasted resources) or too little (automatic fail).

Conduct a formal gap analysis against CMMC Level 2 using NIST 800-171A assessment objectives. Bring in external help if your team lacks bandwidth; a solid one typically costs $10,000 to $40,000.

Deliverables: Defined gaps, prioritized remediation plan, rough budget and schedule estimate.

If gaps look overwhelming (no multi-factor authentication, inadequate logging, loose access controls), accept that full readiness by mid-2026 may not be feasible without aggressive prioritization.

Phase 1: Remediation & Evidence Building (February to June 2026) – The Main Work

This phase consumes most of the time and money.

Address technical controls first (access management, auditing, configuration baselines); they usually take the longest to implement and verify.

Develop documentation: SSP, POA&Ms (follow strict rules; no open critical findings beyond 180 days without strong justification), policies, and procedures.

Test rigorously: Perform internal mock assessments and collect dated, versioned evidence (screenshots, logs, configurations).

Realistic duration: 4 to 9 months for typical organizations. If you start near-compliant, target completion by Q3 2026. If gaps are deeper, extend the window and consider conditional certification paths if they apply.

Budget note: Remediation, tools, and training often run $50,000 to $200,000 or more, plus your internal team time.

Phase 2: Internal Validation & C3PAO Booking (June to August 2026) – Secure Your Slot

Run a complete internal dry-run assessment and close remaining issues.

Select and book a C3PAO immediately; availability is shrinking fast. Check the Cyber AB marketplace, review references, and confirm their Level 2 experience.

Lead times are often 3 to 9 months or longer in current conditions. Schedule the assessment for Q4 2026 or Q1 2027 to stay ahead.

Cost estimate: C3PAO fees range from $30,000 to $75,000, depending on organization size, complexity, and any travel.

Phase 3: Assessment & Certification (September 2026 onward) – Cross the Line

The assessment happens (on-site or virtual, typically 1 to 2 weeks of intense review).

Receive findings and address any non-conformities (usually 90 to 180 days via POA&Ms).

Earn certification (valid for 3 years, with annual affirmations required).

If delays push you past key contract dates, you can still pursue non-CUI work or Level 1 self-assessments, but CUI-eligible contracts become inaccessible.

Hard Truths on Budget and Delays

Total realistic cost for Level 2: $75,000 to $300,000+ spread over 1 to 2 years (remediation drives the bulk; assessment is 20 to 40%).

C3PAO availability crunch: Backlogs reported in early 2026 already force some into 2027 or later. Booking early, even if not fully ready, secures a spot.

Myth check: "POA&Ms fix everything after the assessment." Not true; major or uncorrectable gaps can block certification or require full re-assessment.

Start scoping this quarter. Wait longer, and you compete for fewer assessor slots while remediation backlogs grow.

What's your current readiness level? Have you completed a gap analysis, or are you still figuring out CUI boundaries? That detail changes whether 10 months feels tight or achievable.