Guides · The Deadline Playbook

Plan CMMC readiness around your contract.

The planned Phase II expansion is suspended. Self-assessments and safeguarding obligations continue. Confirm the requirements in your solicitation and contract, then use this 90-day plan to organize the work.

Reviewed October 6, 2026: the planned November 10, 2026 Phase II expansion is suspended. Phase I self-assessment requirements and DFARS safeguarding duties remain. Check your solicitation, contract, and amendments before choosing an assessment path. Sources: official CMMC status and implementation memorandum.

The rules behind the clock

32 CFR Part 170 — the CMMC Program rule — became effective December 16, 2024. It defines the levels, the assessment types, and what "certified" means.

48 CFR (the acquisition rule, revised DFARS 252.204-7021) took effect November 10, 2025. That's the switch that puts CMMC requirements into contracts — and it started a four-phase rollout.

Current status and your contract

Phase 1 · In effect

Self-assessments required at award

Applicable procurements retain CMMC Level 1 or Level 2 self-assessment and affirmation requirements. Check the required level, assessment currency, and SPRS record against the solicitation.

Phase 2 · Suspended

Former transition date is not a current deadline

The November 10, 2026 expansion is suspended. The implementation memorandum limits current CMMC designations to Level 1 or Level 2 self-assessment and directs amendment or modification of affected third-party requirements.

Later phases · Under review

Do not rely on the former schedule

The phased implementation schedule is suspended. Monitor official guidance for any revised schedule rather than treating the former 2027 and 2028 milestones as confirmed deadlines.

Your award · Contract review

Confirm the instrument that governs

Read the actual solicitation, flow-downs, and signed modifications. Resolve conflicting terms with the contracting officer; a program announcement does not itself rewrite your contract.

Supplier diligence remains relevant: primes may request representations or evidence that applicable subcontract requirements are met. Confirm the actual flow-down and requested evidence; a customer questionnaire does not grant access to another contractor's SPRS record.

Want this as a working document? The free companion Phase Checklist turns this playbook into an interactive this-week / this-month / this-quarter list you can print and put on the wall.

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Your 90-day action plan

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Want this playbook mapped to your contracts?

Tell us where you are and a practitioner will come back with your phase exposure, a defensible-score path, and a fixed-scope plan. Or email rj@indirectit.com directly — and try the CMMC Calculator first if you want numbers in hand.