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CMMC / GovConAnswersCISSP · 22 years

CMMC Phase 2 is paused. What do contractors still have to do?

As of 1 October 2026 · this page tracks a moving rule
Short answer

Almost everything except the third-party certificate. Phase 2, which would have required C3PAO Level 2 certification from 10 November 2026, was suspended on 13 July 2026 pending a reform review. DFARS 252.204-7012, all 110 NIST SP 800-171 controls, SPRS scores, CMMC self-assessments and annual affirmations still apply, and so does False Claims Act exposure.

What changed

The suspension

On 13 July 2026 the Department of War suspended Phase 2 of the CMMC rollout and set up a CMMC Reform Task Force for a 60-day review, citing cost and limited assessor capacity. During the suspension, programme managers may not put Level 2 (C3PAO) or Level 3 requirements into new solicitations. Level 1 and Level 2 self-assessment requirements can still appear.

As of 1 October 2026, no Task Force report has been published and no new Phase 2 date has been set. This page will be updated when that changes.

At a glance

Key facts

RequirementStatus
C3PAO Level 2 / DIBCAC Level 3 in new solicitationsSuspended
DFARS 252.204-7012 and NIST SP 800-171 (110 controls)In force
SPRS score and government assessment rightsIn force
Level 1 / Level 2 self-assessments and annual affirmationsIn force where required by contract
False Claims Act liability for misrepresentationUnchanged
Unchanged

What did not pause

  • DFARS 252.204-7012: safeguard CUI with NIST SP 800-171, report incidents to DoD within 72 hours, use cloud providers meeting FedRAMP Moderate or equivalent.
  • NIST SP 800-171 assessment and SPRS: a current score in SPRS, with the government's right to assess.
  • CMMC self-assessments: Level 1 and Level 2 (Self) results posted in SPRS, with annual affirmation by a senior official, where the contract requires them.
  • False Claims Act: the DOJ Civil Cyber-Fraud Initiative pursues contractors who misrepresent their cyber compliance. Settlements continued through 2025 and 2026.
  • Prime contractors: primes can still require C3PAO certification of their subcontractors by contract.
The judgement call

Should you still get certified?

If you handle CUI, the honest answer is that the controls were always required; only the proof changed. C3PAO assessments are still available, certificates remain valid for three years, and over 2,000 Level 2 certificates had been issued by August 2026. For a supplier competing for prime work, a certificate is a differentiator now rather than a mandate. For everyone, an accurate SPRS score and an affirmation you can defend matter more than the timing of the next phase.

In the boardroom

Questions a director should ask

  1. Is our SPRS score current, and would it survive a government assessment tomorrow?
  2. Who signs our annual affirmation, and what evidence do they review before signing?
  3. Have any primes told us they will still require C3PAO certification?
  4. If Phase 2 resumes with a short notice period, how long would we need to be assessment-ready?
Sources
Related answers
CMMC / GovConWhat are the POA&M rules for CMMC Level 2?Cyber oversightWhen does the SEC's four-business-day cyber incident disclosure clock start?Cyber oversightCan directors and CISOs be held personally liable for a cyber breach?
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