CMMC Is Here—and There’s No Grace Period for Defense Contractors

As the Cybersecurity Maturity Model Certification (CMMC) November 10th compliance deadline has passed, companies within the defense industrial base (DIB) must prioritize compliance now or face the consequences. While some defense contractors may have hoped the 43-day federal shutdown might pause or delay upcoming compliance deadlines, that’s not the case. CMMC requirements continue to advance with no extensions, accommodation, or deadline adjustments.

For background, the CMMC framework is designed to ensure defense contractors can properly safeguard controlled unclassified information (CUI) and federal contract information (FCI). Over the next three years, nearly all DoD contractors will have to align with one of three cybersecurity levels outlined in CMMC. Level 1 is self-assessed and covers 15-17 cybersecurity practices that ensure the basic safeguarding of Federal Contracts Information. Level 2 requires the implementation of all 110 security controls from NIST SP 800-171and requires assessment through annual assessment or third-party certification, depending on the sensitivity of information handled. Level 3 pertains to contractors handling information critical to national security and includes an additional 24 enhanced controls (for a total of 134). 

Due to changing standards, many companies that previously met Level 1 requirements must now meet Level 2 requirements. It’s estimated that up to 80,000 firms, plus their subcontractors, will now be vetted under Level 2 cyber hygiene certification, which introduces an additional 110 security practices that dictate how contractors handle controlled unclassified information (CUI). As part of Level 2 preparedness, contractors will need to demonstrate advanced email security, improved employee training, and robust threat detection and response systems, amongst other standards.

Meeting the requirements is not easy. On average, it takes most contractors 6-18 months to prepare for a third-party audit.

Since the DOD did not provide a firm rollout timeline until this fall, many companies have fallen behind in their CMMC compliance preparation.

With the deadline already behind us, companies are beginning to panic, realizing they are at risk but unsure of what steps to take to meet certification requirements.

Outstanding Implementation Challenges & Intensified Bottlenecks

Despite the federal government shutdown, CMMC requirements still became enforceable starting November 10. Even before the shutdown, contractors faced real challenges in meeting CMMC compliance. One of the top CMMC concerns our customers express is that many contractors aren’t receiving enough qualified resources to achieve compliance. While 80,000 companies are required to meet Level 2 compliance, only 70 firms are currently authorized to conduct third-party assessments and certification. These firms, known as C3PAOs (Certified Third-Party Assessor Organizations), and the CMMC Certified Assessors (CCAs) who work under them, are among the only entities qualified to deliver truly effective gap analyses and guidance.

The bottleneck threatens to worsen as contractors scramble to secure limited certification slots within a compressed schedule.

The shutdown introduced additional uncertainty into an already challenging CMMC implementation timeline. While DoD's final CMMC rule has taken effect, as scheduled, regardless of appropriations lapses, contractors face the potential of increased solicitations while simultaneously needing to demonstrate Level 1 or Level 2 compliance. This creates a perfect storm where delayed government operations meet zero-tolerance CMMC enforcement.

Unlike previous regulatory rollouts, CMMC enforcement offers no grace period - since November 10, 2025, all contractors have had to be CMMC compliant at the time they received an award. The shutdown may have delayed solicitation releases, but it did not delay the fundamental requirement that only CMMC-compliant contractors are eligible for awards.

What You Should Do Now

While the November 10th deadline has passed and CMMC assessments can appear daunting, companies must act now to ensure that they are eligible for future DoD contracts and awards. Beginning the compliance process today positions your company to capture opportunities as they arise. Here’s how contractors should approach compliance requirements.

• Conduct gap analyses;
• Review pending contracts;
• Understand CUI;
• Assess business impact;
• Identify internal expertise;
• Secure assessment capacity

Companies should conduct due diligence and identify certified third-party assessors who have previously helped other companies successfully pass CMMC assessments. Assessors who have not yet supported companies in passing CMMC assessments should be weeded out, as they only increase the risks of CMMC non-compliance.

Once companies identify their compliance gaps, they should assess whether their current IT environment can support CMMC requirements. Companies relying on managed service providers (MSPs) or cloud service providers (CSPs) must carefully select their providers, since a provider's cybersecurity capabilities can determine certification success.

Companies should work with qualified third-party assessors to evaluate their current IT provider's CMMC readiness. Key considerations include whether a provider understands CUI handling requirements and displays an adaptability to evolving CMMC standards.

If a company’s current provider falls short, they should prioritize service providers who are currently pursuing FedRAMP authorization. This federal certification process indicates that providers are already implementing the rigorous, continuously updated security controls required by federal agencies.

FedRAMP-authorized or FedRAMP-pursuing providers offer a strategic advantage: they've invested in security frameworks that evolve alongside federal requirements, reducing the risk of future compliance gaps.

Looking Forward: Post-Reopening CMMC Reality Check

With the federal government now fully operational, defense contractors face an accelerated compliance landscape that demands immediate action. The reopening has triggered a surge in contract solicitations that were delayed during the shutdown, creating an unprecedented volume of opportunities - but only for CMMC-compliant contractors.

The post-shutdown environment has also revealed the true scope of the assessment bottleneck: C3PAO organizations are reporting months-long booking backlogs, while many contractors are discovering that their self-assessed Level 1 compliance was insufficient for the rigor of third-party validation.

Companies still pursuing certification should expect longer wait times, higher assessment costs, and increased scrutiny as the pool of compliant contractors becomes the new competitive baseline.

It’s clear that CMMC compliance is no longer a future requirement, but a present-day market-entry barrier that will determine which companies survive in the evolving defense industrial base.

Companies that treated the shutdown as an opportunity to accelerate compliance efforts will emerge stronger, while those that used the shutdown as an excuse to delay or remain inactive could be eliminated from the defense contracting ecosystem altogether.