CMMC 2.0 Enforcement Is Here: What Defense Contractors Must Know Before November 10

The waiting is over. On September 10, 2025, CFR 48 was published in the Federal Register, officially setting November 10, 2025, as the start of CMMC 2.0 Phase 1 enforcement. For defense contractors, this isn’t just another compliance deadline — it’s a fundamental shift in how the Department of Defense will award contracts. The message is clear: no CMMC certificate, no bid.

Understanding CMMC 2.0 and CFR 48

The Cybersecurity Maturity Model Certification (CMMC) 2.0 represents the DoD’s answer to years of ineffective self-attestation under NIST SP 800-171. While contractors have been required to protect controlled unclassified information (CUI) since 2017, enforcement has been minimal and inconsistent. CFR 48 changes that reality permanently.

Under the new rule, contracting officers gain the authority — and obligation — to include CMMC requirements in solicitations and awards starting November 10. This isn’t a soft launch or pilot program. Once enforcement begins, CMMC compliance becomes as essential as having a CAGE code or DUNS number.

The framework establishes three levels of certification:

• Level 1 (Foundational): 17 practices for federal contract information (FCI)
• Level 2 (Advanced): 110 practices aligned with NIST SP 800-171
• Level 3 (Expert): 110+ practices based on NIST SP 800-172

Most manufacturers handling CUI will require Level 2 certification from a Third Party Assessment Organization (C3PAO). Self-assessment options may exist for some Level 1 and 2 contracts initially, but the DoD has made clear these are temporary measures, not long-term strategies.

The Impact on Defense Contractors

Immediate Contract Implications

Starting November 10, defense contractors will encounter CMMC requirements in new solicitations. The DoD has indicated that adoption will be progressive but swift. Prime contractors should expect CMMC clauses in virtually all new contracts involving CUI by early 2026.

For small and medium manufacturers — the backbone of the defense supply chain — this creates an existential challenge. Unlike large primes with dedicated compliance teams, smaller contractors must achieve the same certification standards with limited resources. A machine shop with 75 employees faces the same 110 controls as a billion-dollar aerospace firm.

The Flow-Down Effect

DFARS 252.204-7020 mandates that prime contractors flow down CMMC requirements to all subcontractors handling CUI. This creates a cascade effect throughout the defense industrial base. If you’re a Tier 2 or Tier 3 supplier, your prime contractor will demand proof of CMMC compliance — or find suppliers who can provide it.

We’re already seeing forward-thinking primes vetting their supply chains. Those unable to demonstrate clear paths to certification are being replaced. By waiting, contractors risk not just future opportunities but existing relationships.

The Assessment Bottleneck

Perhaps the most overlooked risk is assessment capacity. With fewer than 100 accredited C3PAOs currently authorized to perform assessments, and each Level 2 assessment requiring weeks to complete, simple math reveals a looming crisis. Thousands of contractors need certification, but there are only a handful of assessors to provide it.

Early movers are already booking assessments for Q1 2026. Those who wait until the November deadline approaches may find themselves in an impossible position: ready for assessment but unable to schedule one before critical contract deadlines.

Critical Steps for Immediate Action

1. Define Your CMMC Scope

Before anything else, understand what needs protection. Many contractors overscope their environments, dramatically increasing costs and complexity. Proper scoping involves:

• Identifying all CUI types in your environment
• Mapping data flows from receipt through destruction
• Establishing clear boundaries for your assessment
• Considering enclave strategies to minimize scope

This foundational step often reveals that CUI touches more systems than expected — or conversely, that strategic segmentation can significantly reduce compliance burden.

2. Conduct an Honest Gap Assessment

Hoping you’re compliant isn’t a strategy. A thorough gap assessment against CMMC Level 2 requirements will reveal the true magnitude of work required. Common gaps include:

• Incomplete or missing system security plans (SSP)
• Lack of formal incident response procedures
• Inadequate access control documentation
• Missing or outdated security awareness training

Document every gap in a formal Plan of Action and Milestones (POA&M). C3PAO assessors will expect to see not just current compliance, but evidence of how you identified and remediated deficiencies.

3. Build Your Evidence Repository

CMMC assessment isn’t just about having controls — it’s about proving they exist and function. Begin collecting:

• Policy and procedure documentation
• Configuration screenshots and system logs
• Training records and acknowledgments
• Incident response test results
• Vendor management documentation

This evidence collection often takes months. Starting now means avoiding the pre-assessment scramble that derails many certification efforts.

4. Secure Your Assessment Partner

With C3PAO capacity already constrained, establishing a relationship now is critical. But choose carefully — not all C3PAOs are equal. Look for:

• Proven track record with similar-sized manufacturers
• Clear communication about timelines and costs
• Willingness to provide pre-assessment readiness reviews
• Established relationships with the Cyber AB

The right partner guides you through preparation, not just assessment.

The Cost of Inaction

Some contractors still hope for delays or exceptions. This is dangerous thinking. The DoD has invested too much in CMMC to go back on it now. CFR 48’s publication ended years of speculation — enforcement is happening.

The mathematics of noncompliance are stark. Miss CMMC requirements on one contract, and you’re disqualified. As CMMC adoption accelerates through 2026, noncompliant contractors will find themselves locked out of the entire defense market. For many small manufacturers, this means choosing between certification costs today or business extinction tomorrow.

DataSure24: Your Path to CMMC Compliance

At DataSure24, we’ve guided dozens of manufacturers through successful CMMC preparation. Our Lead CCAs and provisional instructors understand both the technical requirements and the business realities facing defense contractors.

Our proven approach includes:

• Comprehensive scoping to minimize assessment boundaries
• Gap assessments that reveal real requirements, not worst-case scenarios
• 12-month readiness programs that spread costs and effort
• Direct C3PAO partnerships ensuring assessment scheduling
• Post-certification support for continuous compliance

The November 10 deadline isn’t negotiable, but your readiness timeline is still within your control. Every day of delay increases risk and reduces options.

Ready to secure your defense contracts? Contact DataSure24 today for a complimentary CMMC readiness consultation. Let’s ensure November 10 marks your competitive advantage, not your compliance crisis.

For more information about CMMC requirements and DataSure24’s certification services, visit https://datasure24.com/services/ or call 716-600-3724.

Posted by Mark Musone