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The Department of Defense has finalized the Cybersecurity Maturity Model Certification, making compliance a binding requirement for defense contractors. This is not a recommendation or a guideline—it is mandatory for any organization handling Federal Contract Information or Controlled Unclassified Information. If your business works with DoD contracts in any capacity, you must be prepared to demonstrate compliance.
The framework is divided into three certification levels. Level 1 applies to FCI only and requires an annual self-assessment. Level 2 applies to CUI and requires either a self-assessment for low-risk contracts or a third-party review for higher-risk contracts. Level 3 is reserved for the most sensitive CUI environments and requires direct assessment by DIBCAC. These levels are designed to match the sensitivity of the information you manage with the level of scrutiny required to protect it.
Conditional status exists for Levels 2 and 3, but it is limited. Contractors may be awarded contracts with a 180-day window to close identified gaps if a Plan of Action and Milestones is in place. Failure to resolve those gaps within the allowed period will result in loss of certification status. Level 1 has no conditional pathway—final certification is required at the time of award.
The first step is knowing exactly which CMMC level your contracts require. If your work involves only Federal Contract Information, you fall into Level 1. If your work involves Controlled Unclassified Information, you fall into Level 2 or Level 3 depending on the sensitivity of the contract. Level 2 requires full alignment with NIST 800-171. Low-risk contracts at Level 2 may permit self-assessments, while higher-risk contracts require a Certified Third-Party Assessment Organization. Level 3 involves the highest risk and is assessed directly by DIBCAC.
Next, you must define scope. Every system that processes, stores, or transmits FCI or CUI must be identified. Assign a unique identifier to each system, document the boundaries, and determine which assets fall inside those boundaries. Scope is the foundation of compliance because it determines the controls you must apply, the evidence you must provide, and the cost and time required to achieve certification. Without clear scope, your compliance program will fail.
Finally, you must enforce subcontractor compliance. If you are a prime contractor, you are responsible for ensuring that every subcontractor who handles FCI or CUI has the proper certification at the required level. This verification must take place before awarding a subcontract. Keep formal records of each subcontractor’s certification status as part of your compliance program. This is not optional; it is an enforceable requirement under the final rule.
CMMC is not a distant requirement. The rule is already in effect, and solicitations can include CMMC language today. The Department of Defense has confirmed a phased rollout that will extend over several years, with full enforcement scheduled for November 2028. Waiting until the final deadline will put your business at risk of being locked out of contracts long before that date.
The rollout is structured into four phases. Phase 1 has already begun, allowing contracting officers to insert CMMC requirements into new awards. Phase 2 will expand the requirement further, Phase 3 will tighten oversight, and Phase 4 will make CMMC mandatory across nearly all DoD contracts. The progression is intentional, giving contractors a limited window to prepare while steadily raising the bar for compliance.
Every contractor should map their compliance efforts to this schedule. Align remediation projects, gap closures, and assessment scheduling with the phase dates. Secure a third-party assessment window early if you require one—waiting lists are already growing. If you plan to rely on conditional status, make sure your Plan of Action and Milestones is ready and realistic, because missing deadlines inside that 180-day allowance will remove your eligibility. Treat the rollout as a set of hard business milestones, not as guidelines.
Compliance is not a one-time exercise. It requires a structured approach that proves readiness at the start and maintains discipline every day after certification. The most effective way to begin is with a readiness assessment. Map each NIST 800-171 requirement, identify where your organization falls short, and create an evidence register that links controls to policies, technical configurations, and monitoring data. This register becomes the backbone of your audit defense and must be updated continuously.
If you anticipate using conditional status at Level 2 or Level 3, prepare a realistic Plan of Action and Milestones. Conditional status is limited to 180 days. Use that window to close only manageable gaps. Prioritize the highest-impact controls that protect confidentiality and availability. Contractors who treat conditional status as a crutch rather than a short-term allowance risk losing eligibility before the contract is underway.
Accuracy and accountability are equally important. Your entries in the Supplier Performance Risk System must match your actual security posture. A senior official is required to provide an annual affirmation of compliance, and that affirmation must be backed by evidence. Misstatements or false reporting open the door to contract penalties and legal action under the False Claims Act.
To sustain compliance, contractors must integrate monitoring, incident response, and staff training into daily operations. Compliance documentation should be reviewed quarterly, security tools should be tested regularly, and subcontractors must be reverified to confirm their certifications remain valid. By treating CMMC as an ongoing business function, not a one-time hurdle, you ensure your contracts remain protected, your reputation secure, and your organization prepared for future audits.
Get in touch now and let Triton Technologies put the right program in place for your business.
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