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The Cybersecurity Maturity Model Certification is mandatory for all federal and DoD contractors and subcontractors. Formalized in 2024, the rule enforces certification levels based on the volumes and types of controlled unclassified information (CUI) and federal contract information (FCI) the contractor handles. 

The Final Rule was sent by the DoD to the Office of Information and Regulatory Affairs (OIRA) in July, with full implementation expected by 2026. Although we don't know precisely when OIRA will complete its review, it may take between 90 and 120 days, followed by an additional one to three weeks for the Federal Register to publish. 

The rule is expected to be enforceable upon publication; as there will be no delay or grace periods, this should put us into October at the earliest (the most likely scenario) or by February 2026 at the latest, should there be any classification changes or delays.

This most recent update introduces specific contract clause language to be included in every federal and defense contract, thereby increasing enforceability across the defense ecosystem. 

It should be noted that the implementation of the final rule does not change any of the standing CMMC requirements. What it does do is provide language to be inserted into existing and new contracts, authorizes contracting organizations to use this language in their solicitations, and marks the beginning of the official CMMC phased rollout. 

Is Your Organization CMMC Ready? 

CMMC certification is a requirement for any prime contractor bidding on DoD contracts. It is also required for subcontractors working in the defense industrial realm. If your organization currently holds or plans to bid on DoD contracts in 2025, certification will be required, with levels based on the type of CUI involved. 

For organizations that have not yet obtained their Level 2 certification, a CMMC readiness assessment is the first step towards compliance. 

With more than six times the security requirements as Level 1, Level 2 is vastly more complex. Assessments are conducted by a certified third-party assessment organization (C3PAO) and must be renewed every three years unless the organization undergoes "significant changes," which may trigger a reassessment. 

For previously certified organizations, the contract rule should trigger a review of all current contracts to ensure CMMC language is included. All subcontractors, including supply chains, must be compliant by Q1 2026, so there is no time to delay. 

In terms of certification deadlines, the most critical metric for contractors to be aware of is the procurement administrative lead time (PT) – the period between the solicitation and contract award dates. 

For example, if your customer typically takes three to four months to award a contract following the solicitation, the contractor must be certified before they can accept the award. However, waiting for the solicitation to initiate a certification is unwise. It can take three months or more to go through an assessment, and a significant amount of effort must be expended to improve the organization's chances of passing. 

Many contractors discover issues too late—sometimes during the assessment itself. A CMMC readiness assessment reveals critical vulnerabilities, allowing them to be remediated before the C3PAO.

The Bottom Line

 The 48 CFR Final Rule's contract clause requirements are set to take effect imminently, marking the start of the official CMMC rollout. Essendis provides comprehensive CMMC readiness assessments that cover all requirements, including critical documentation and contracts, accelerating compliance timelines and improving your chances of acing the C3PAO. 

Connect with a CMMC advisor today to start your journey.