November 10, 2026 is rapidly approaching, and while many OSCs are preparing many are still unsure what this date means. We've got you covered with an overview, and a checklist of actions you can take now to prepare, but you will want to begin as soon as possible.
November 10, 2026 Explained - And Why It Matters
This milestone marks the start of CMMC Phase 2, in which CMMC requirements evolve from self-attestation to independent third-party validation.
This transition means CMMC compliance is no longer a project for your team to manage internally. Now, an OSC will need to get on the calendar with a C3PAO. As a result, demand for C3PAO assessments is beginning to outpace availability.
Here are some actions you can take now to prepare.
Step 1: Minimize Your Footprint
One effective way to prepare is to reduce the amount of infrastructure that needs to be assessed.
- Identify your CUI: Clearly map where CUI is stored, processed, and transmitted.
- Consider Enterprise or Enclave: Determine if you can isolate CUI into a secure, dedicated enclave or if you need to include your entire enterprise. By limiting the scope to a specific environment, you drastically reduce the complexity of your audit and the cost of remediation.
- Purge unnecessary data: If you no longer need historical CUI, securely dispose of it. Less data equals less risk.
Step 2: Evidence over Documentation
Assessors do not just want to see your policies; they want to see that those policies are working in real-time. Some considerations:
- Audit your logs: Ensure your systems are generating and storing logs. Be able to demonstrate that they have reviewed them. An assessor will ask, "Show me how you detected this event," not "Show me your incident response policy."
- Standardize configuration reports: Consolidate your hardware and software inventory. You must be able to prove that every device in scope is patched and configured according to NIST 800-171 standards.
- Identify all assets: Ensure you identify People, Facilities, and Technology as CUI, SPA, CRMA, Specialized, or Out of Scope
- Create an "Evidence Locker": Organize your screenshots, configuration reports, and training records into a single, accessible repository. Being able to retrieve evidence on demand during an assessment is the hallmark of a high-functioning team.
Step 3: The SPRS Reality Check
Your SPRS score is not just a data point; it is a legal representation of your security posture.
- Verify your score: Cross-reference your current SPRS score with your actual system configuration.
- Eliminate "wishful thinking": If a control is not fully implemented, do not claim it is. Inaccurate SPRS reporting is a primary target for oversight and can lead to severe False Claims Act (FCA) implications.
- Plan for POA&Ms: While some items may still be eligible for a Plan of Action and Milestones (POA&M), prioritize closing these gaps immediately to ensure you have no POA&Ms before an assessor arrives.
Step 4: Proactive Scheduling
The C3PAO bottleneck is a real threat for businesses who wait too long.
- Assess your status: Honestly evaluate your internal timeline. Are you truly ready for an audit, or are you still building your foundation?
- Schedule with a C3PAO ASAP: Do not wait for a contract solicitation to arrive or to have your solution completely built before looking for an assessor. Reach out to us today to understand scheduling and lead times.
- Secure your slot: Get on the calendar for late 2026 or early 2027. Locking in an assessment window early is the best way to ensure you don’t lose out on new contract opportunities due to a lack of certification.
- Primes: Many Primes are requiring a C3PAO certification by specific dates as they want to reduce their risk of not having a subcontractor available for a proposal.
Talk To An Expert Today
If you are uncertain where to begin, we're a quick phone call away. Schedule some time with one of our experts, and we can help you determine where you are in the journey and your next steps.