DoD has paused the transition to CMMC Phase 2 while it reviews the program. Phase 1 and existing DFARS/NIST SP 800-171 obligations remain in effect.
If a solicitation or subcontract requires a specific CMMC status, the contractor or subcontractor must meet that requirement before award or performance, as stated in the clause. Find out exactly where your business stands today.
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Your IT team may have purchased tools. Your compliance lead may have built a spreadsheet. But if leadership has not made the decisions CMMC actually requires, none of that work protects your contract eligibility.
The requirements written into your contracts don't disappear because the broader program is under review. Falling short of a CMMC status a specific contract requires can affect cash flow, staffing decisions, and your standing with prime contractors.
As of September 2026, the Department of Defense has suspended the transition to CMMC Phase 2 while it reviews the program. Phase 1 requirements and existing DFARS and NIST SP 800-171 obligations remain in effect. Contractors and subcontractors should follow the CMMC level and assessment requirement written into each solicitation, contract, or subcontract.
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