CMMC is Here: DoD’s Final Push Makes It Real for Oct 2025

New Directive from Secretary of Defense

As a valuable contributor to the Defense Industrial Base (DIB), you know cybersecurity is a critical component of our national security. Recent actions and announcements from the Department of Defense (DoD) underscore this reality with vigorous urgency, particularly concerning the Cybersecurity Maturity Model Certification (CMMC).

CMMC: It’s Really Here

The CMMC framework became final in December 2024 with the publication of 32 CFR part 170.  

But 48 CFR is the contractual “on-ramp” and enforcement mechanism via the DFARS.  It’s now in final review with the OMB’s OIRA and is considered more of a procedural formality following the 32 CFR final rule. And it’s the final hurdle before CMMC requirements become mandatory in DoD contracts.

What does this mean for your business?

• No More Delays or Doubts: The OMB review typically takes 60 days. Once cleared, the rule is expected to be effective immediately upon publication in the Federal Register. The DoD has been publicly and emphatically saying that CMMC is here and isn’t going away.  The DIB should expect to see CMMC requirements appear in DoD contract solicitations as early as October 1, 2025.
• The “Red Light Flashing” Moment: With the average defense contractor needing 6-12 months to achieve assessment readiness, if you’ve waited until the 48 CFR rule becomes, you are already behind. The time to determine your state of readiness is now.

Why You Need to Book Your CMMC Level 2 Assessment ASAP

Getting ahead of your CMMC assessment isn’t just about compliance; it’s about securing your future in the DIB:

• Competitive Advantage & Contract Eligibility: CMMC becomes a mandatory prerequisite for DoD contracts involving Controlled Unclassified Information (CUI). Early certification gives you a significant competitive edge over those scrambling at the last minute. Remember, CMMC requirements will flow down through the supply chain, making certification a key decision factor for prime contractors when selecting partners.
  
• Enhanced Stature with the DoD: Going through the assessment process inherently strengthens your defenses against evolving cyber threats, protecting your sensitive data, intellectual property, and status with the DoD. This reduces your risk of costly breaches and operational disruptions.
  
• Avoid Penalties and Delays: CMMC 2.0 places greater accountability on DIB companies, including the potential for penalties under the False Claims Act for misrepresenting your cybersecurity posture. Senior officials will be required to provide annual affirmations of compliance, reinforcing the gravity of these requirements.
  
• Limited Assessor Availability: The number of authorized CMMC Third-Party Assessor Organizations (C3PAOs) is limited: One for every 1,000 companies requiring CMMC Level 2 certification, per the DoD. C3PAO assessment demand has surged, booking an assessment has become increasingly difficult and likely to become more expensive. Those who wait will likely face long queues and missed DoD contract opportunities.
  
• Phased, But Imminent: While you should expect that full implementation across all applicable contracts will be phased in, the described year over year timeline is more of a DoD-announced objective and guidance rather than a formally described, legally binding schedule within the 32 CFR Part 170 CMMC Program Rule. So you should also expect to begin seeing CMMC requirements as soon as October 2025.

The message from the DoD is that cybersecurity is a renewed national security imperative, and CMMC is the bedrock of that security for the DIB. Don’t let your business be left behind.

We encourage you to prioritize your CMMC assessment readiness and engagement with an authorized C3PAO immediately. Your proactive steps today will ensure your continued eligibility and success in the vital mission of supporting our national defense.

Call today at 617-314-9721  x158 or email us at [email protected]

We look forward to talking with you.