The CMMC implementation timeline is no longer a distant concern for DoD contractors, it’s an urgent priority. The Department of Defense (DoD) is enforcing cybersecurity requirements through the Cybersecurity Maturity Model Certification (CMMC) 2.0 framework, with all new contracts requiring compliance by 2026. At the same time, the Defense Federal Acquisition Regulation Supplement (DFARS) requires organizations to implement NIST SP 800-171 controls as the baseline for security.
Delaying CMMC implementation now puts contractors at risk of disqualification from future defense contracts, a risk that will only grow as competition intensifies.
The Final Rule Is In, And the Clock Is Ticking
On June 27, 2024, the Department of Defense (DoD) submitted the final CMMC rule to the Office of Information and Regulatory Affairs (OIRA). It was officially published in the Federal Register on December 26, 2024, starting the countdown for full enforcement of the CMMC implementation timeline.
Here’s what contractors need to know:
- Early 2025: Revised DFARS clauses (252.204-7012, -7019, -7020, -7021) were finalized.
- Mid-2025: New DoD contracts began requiring CMMC compliance, marking a critical phase in the rollout.
- October 1, 2026: All new contracts will require CMMC certification at Levels 1, 2, or 3.
If your organization hasn’t started a CMMC readiness assessment, now is the time to act delays could put future contracts at risk.
What Maturity Level Applies to You?
As part of the CMMC implementation timeline, contractors must understand which maturity level applies to their contracts. The CMMC framework includes three levels:
- Level 1: Foundational: For contractors handling Federal Contract Information (FCI). Requires 17 basic practices and allows for self-assessment.
- Level 2: Advanced: For contractors managing Controlled Unclassified Information (CUI). Requires all 110 practices from NIST SP 800-171. A third-party assessment is required for high-priority contracts.
- Level 3: Expert: For contractors exposed to Advanced Persistent Threats (APTs). Requires additional practices from NIST SP 800-172 and a government-led assessment.
Most small and mid-sized defense contractors will need to achieve CMMC Level 2 compliance, which means fully implementing NIST SP 800-171 controls and preparing for a formal assessment.
A Quick Look Back and What’s Ahead
The CMMC implementation timeline has evolved significantly since its early projections. Back in 2020, the Department of Defense (DoD) expected 7,500 certifications by 2021. That target was quickly revised to a smaller 15 Prime Acquisitions for the initial rollout.
Since then, the phased schedule has become clearer:
- FY2022: 75 Prime Acquisitions
- FY2023: 250 Prime Acquisitions
- FY2024: 325 Prime Acquisitions
- FY2025: 475 Prime Acquisitions
This gradual rollout gave both the DoD and contractors time to prepare. But by October 2026, CMMC compliance will be mandatory for all new contracts, making it the final deadline that no contractor can afford to miss.
Preparing Now: The Path to Certification
To stay competitive and meet the CMMC implementation timeline, contractors should begin their compliance process with these key steps:
- Identify Your Required Maturity Level: Determine which CMMC level applies to your contracts based on the sensitivity of the data you handle.
- Conduct a Readiness Assessment: Perform a gap analysis aligned with NIST SP 800-171 requirements to understand where improvements are needed.
- Remediate Gaps and Document Controls: Update policies, procedures, and technical protections to close compliance gaps.
- Engage a C3PAO (Level 2+): Work with a Certified Third-Party Assessment Organization to complete the required formal certification.
The CMMC verification timeline will vary depending on contract type, urgency, and level. That’s why proactive preparation is critical to avoid delays that could cost you future contracts
Take Action Now: Start Your CMMC Implementation
CMMC is more than a regulatory requirement, it’s a competitive advantage. Contractors that act early in the CMMC implementation timeline will be better positioned to win and retain valuable DoD contracts.
As an authorized C3PAO, RSI Security is your trusted partner for CMMC implementation and certification. We provide:
- End-to-end CMMC readiness assessments
- Remediation planning and guidance
- Official CMMC Level 2 assessments
Don’t let compliance become the barrier between your business and the next DoD opportunity. Contact RSI Security today to begin your CMMC compliance journey and secure your place in future contracts.
Discover how RSI Security can help your organization.
Download Our CMMC Checklist
