After years of drafts, delays, and speculation, the Department of War (DoW) is set to implement CMMC on November 10, 2025. This date marks the beginning of the first phase of the program’s formal rollout, a moment many contractors have been waiting (and worrying) for.
But what actually happens on Day 1?
A Phased Start, Not a Cliff
CMMC won’t blanket the entire DIB overnight. The rollout plan introduces requirements gradually through four phases, concluding in 2028 when all solicitations will include CMMC language.
Though the formal process is phased over a few years, we're already seeing major defense contractors signal a more rapid timeline throughout their supply chains.
Those who’ve been aligning with NIST SP 800-171 will be ahead of the curve.
Those who haven’t will feel the friction.
Be Prepared
There are still a lot of unknowns ahead, especially around assessment timelines as a result of the limited availability of assessors, reciprocity for existing certifications, and consistency among third-party assessment organizations (C3PAOs).
For contractors, the takeaway is to control what you can control and document everything!
Day-1 Success Checklist
Here’s what “ready for Day 1” looks like:
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System Security Plan (SSP): Current, complete, and mapped to 800-171A controls.
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Asset Identification: Clear scoping of CUI and relevant systems.
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Vendor Assurance: Confirm your supply chain understands CMMC flow-down obligations.
We’ve seen that organizations with clean documentation and control of ownership outperform others, not just in compliance, but in business continuity.
Take Action Now
There’s a temptation to wait for the dust to settle, but waiting carries risk. Once contracts start including CMMC language, eligibility becomes an either/or scenario; you’re either compliant or not, either you win a contract, or you are not eligible to win.
Early engagement with a C3PAO means:
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Shorter lead times for assessment slots
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Predictable costs and scheduling
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Fewer rework cycles
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Greater confidence with customers and auditors
Remember, the intent behind CMMC isn’t punishment; it’s to protect the ecosystem. November 10 isn’t just a deadline; it’s the starting line for a new baseline in defense cybersecurity.
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