CMMC 2.0 Enforcement Begins: Is Your Business Ready?

Think compliance with the Cybersecurity Maturity Model Certification (CMMC) requirements is still a distant problem? Think again. As of Monday, November 10, 2025, the Department of Defense (DoD) has started embedding the CMMC 2.0 framework into contracts and solicitations. This comes after the publication of a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS), officially authorizing CMMC requirements in DoD contracts.

In this blog, we will unpack how this regulatory development affects your business and reshapes the defense contracting landscape. Plus, we’ll show how Techmedics can help your business navigate this change and ensure compliance.

Understanding the Three CMMC 2.0 Levels

The original CMMC 1.0 framework had five levels of cybersecurity maturity. However, CMMC 2.0 simplifies this tiered model to just three:

Level 1: Foundational

This is the basic entry point for all organizations looking to comply with CMMC. Level 1 is designated for protecting FCI, or information provided by or generated for the government under contract, not intended for public release. This includes project proposals, contractor performance data, pricing, and delivery schedules.

Its goal is to establish basic cyber hygiene, which can be achieved by implementing 17 fundamental cybersecurity practices. These include:

• Authenticating users before providing access through passwords and multifactor authentication

• Ensuring sensitive information is removed from storage devices like hard drives, CDs, and phones before disposing of or reusing them

• Limiting access to media containing FCI to authorized users

• Identifying, reporting, and patching system vulnerabilities promptly

• Using antivirus software and endpoint protection tools to secure systems from malware.

Level 1 compliance is demonstrated through a yearly self-assessment conducted by the company, with a senior official submitting an affirmation of compliance to the DoD’s Supplier Performance Risk System (SPRS).

Level 2: Advanced

Level 2 is the core requirement for many businesses in the defense supply chain, focusing on protecting CUI and other sensitive data that require legal safeguards.

Unlike Level 1, which only requires the implementation of 17 security controls, Level 2 elevates the scope and complexity with 110 controls based entirely on the NIST SP 800-171 cybersecurity framework. It also requires extensive documentation, such as a System Security Plan (SSP) and Plan of Action and Milestones (POA&M).

When it comes to Level 2 assessments, the DoD determines whether a contract needs a self-assessment or a C3PAO evaluation based on the CUI’s sensitivity. C3PAOs are independent, accredited companies authorized to conduct cybersecurity evaluations for DoD contractors, ensuring they adhere to CMMC security standards.

Self-assessments are permitted for less critical programs, while the C3PAO evaluations are required for high-risk programs like advanced research and development, supply chain security, and weapons development.

Level 3: Expert

Reserved for organizations handling the DoD’s most critical CUI and sensitive programs, Level 3 is designed to defend against advanced persistent threats (APTs) and other sophisticated cyber adversaries.

While this level includes all 110 NIST 800-171 controls seen in Level 2, defense contractors and their partners must also consider additional security controls from NIST SP 800-172 and other DoD-specific mandates.  

Given the sensitivity of the programs tied to national defense and weapons systems, assessments at this level are directly conducted by the DoD. This ensures complete oversight and assurance over critical data.

CMMC 2.0’s Phased Rollout Timeline

Following the DFARS’ publication of the final rule, the DoD is now implementing CMMC 2.0 in stages. The rollout is divided into four phases:

Phase 1

Start Date: November 10, 2025

During this stage, the DoD starts requiring CMMC Level 1 or 2 certifications for select contracts and solicitations. To become eligible for these, organizations may be asked to perform self-assessments, achieve a specific SPRS score, and submit their results and affirmation.

Phase 2

Start Date: One year after Phase 1 (November 10, 2026)

Contracts that involve CUI now require a Level 2 certification. Organizations that are bidding on or have been awarded these contracts must undergo an assessment by an authorized C3PAO to achieve compliance at this level.

Phase 3

Start Date: One year after Phase 2 (November 10, 2027)

The DoD starts requiring CMMC Level 3 Certification Assessments for certain contracts that involve high-value CUI associated with critical national defense initiatives. These rigorous assessments, conducted by the DIBCAC, demand deep cybersecurity maturity, including proactive threat detection and incident response.

Phase 4

Start Date: One year after Phase 3 (November 10, 2028)

During this phase, all DoD contracts and solicitations that involve FCI or CUI are expected to include the appropriate CMMC level requirement:

• Level 1 Self-Assessment

• Level 2 Self-Assessment

• Level 2 Certification (via C3PAO)

• Level 3 Certification (via DIBCAC)

To remain eligible for DoD business, organizations must ensure full compliance with the required level specified in each contract.

What is the Enforcement Impact of CMMC on Defense Contractors?

Before the framework’s rollout in November 2025, CMMC functioned as a roadmap to guide defense contractors toward better cybersecurity practices.  

DoD expected organizations to conduct self-assessments, follow NIST SP 800-171 guidelines, and prepare for future CMMC compliance. However, there was no proper enforcement system, and CMMC requirements were not yet embedded in contracts.  

But with the framework now being implemented, CMMC has become a contractual obligation for organizations instead of just being a voluntary guiding document. This means contractors must be certified at the appropriate level before being awarded contracts that involve FCI and CUI, creating a steep compliance cliff.

By failing to meet the new requirements, organizations may suffer the following:

• Project Ineligibility: Defense contractors are automatically disqualified from bidding if a solicitation requires CMMC compliance. For existing contracts, failing to comply with the latest CMMC terms could result in non-renewal or loss of future task orders.

• Reputational Damage: Contractors who misreport their compliance or fail assessments risk being flagged in government systems like the SPRS, resulting in exclusion from future opportunities and loss of trust across the defense industry.

• Legal Liability: A defense contractor submitting a proposal or uploading a compliance affirmation to the SPRS without actually meeting the requirements commits material misrepresentation.  
  
  Under the False Claims Act of 1863, this can lead to civil penalties and whistleblower actions from competitors or employees. This may also lead to treble damages, where a court triples the amount of actual damages the government suffered as a result of a defense contractor’s misrepresentation.

Understanding CMMC 2.0 Flow-Down Requirements

CMMC 2.0 compliance isn’t just limited to defense contractors, also known as primes. The DoD built flow-down into the framework’s rule set to guarantee the end-to-end protection of defense information. This means contractors must also extend cybersecurity requirements to the following:

• Subcontractors: These are businesses that support a prime by offering goods or services related to a DoD contract or solicitation. They must comply with CMMC even if they don’t directly interact with the DoD.

• Suppliers and Vendors: These entities must adhere to CMMC requirements if they process, store, or transmit FCI or CUI.

• Third-Party Service Providers and IT Companies: If they manage networks or systems that deal with DoD-related data, they become a part of the flow-down.

Because the prime defense contractor is responsible for the cybersecurity of the whole chain, they must perform the following to fulfill the flow-down requirement:

• Include Specific Clauses: Make sure to indicate compliance requirements and the correct CMMC level in all subcontracts.

• Verify Compliance: Before awarding tasks to subcontractors, always verify their affirmation of compliance or CMMC certification. Do not accept any pledges to comply at a later date.

• Monitor: Make sure subcontractors and other organizations maintain their CMMC compliance status during contract periods.

How Techmedics Can Help You Achieve CMMC 2.0 Compliance

Adhering to the many requirements of the CMMC 2.0 framework can be overwhelming, but you don’t have to do it all alone. Why not partner with an experienced managed IT services provider like Techmedics? Our four-step process ensures a strong cybersecurity posture for your business, making compliance with CMMC 2.0 a breeze.

1. Gap Assessment: This identifies the areas of your cybersecurity initiative where you are falling short. It involves reviewing existing policies and controls, mapping them against required practices, and developing a remediation plan.

2. NIST SP 800-171 Alignment: This step is about configuring your systems and procedures to meet the 110 security controls outlined in NIST SP 800-171, helping you prepare for Level 2 certification.

3. Cybersecurity Implementation: Our team deploys technical controls like firewalls, multifactor authentication, strong password policies, and endpoint protection to fortify your cyber defenses. We also train your staff on cybersecurity best practices and update the necessary policies and procedures.

4. Ongoing Monitoring: Techmedics doesn’t stop after implementing security solutions. We also continuously scan for vulnerabilities and security issues that may jeopardize your CMMC 2.0 compliance.  

Techmedics serves businesses of all sizes in Dallas, Denver, Los Angeles, Las Vegas, and Phoenix.  

Don’t be caught off guard when the next DoD contract demands CMMC 2.0 compliance. Contact us today for a FREE consultation.  

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