CMMC Final Rule Countdown: Less Than 30 Days to Enforcement

The clock is ticking — enforcement begins November 10th.

The countdown is officially on. As of today, the Defense Industrial Base (DIB) is less than 30 days away from the CMMC Final Rule (48 CFR DFARS Acquisition Rule) taking effect on November 10, 2025.

From that date forward, CMMC compliance will be required for all new solicitations and contracts. Whether you’re a prime contractor or a small business supplier, the next few weeks are critical, and they determine whether your organization is ready to bid, ready to certify, and ready to continue doing business.

What Happens on November 10, 2025

According to the CMMC FAQs (September 2025), the revised DFARS 252.204-7021 clause officially takes effect on November 10th, launching Phase 1 of CMMC implementation.

• Phase 1 (first 12 months): Focuses on self-assessments aligned with NIST SP 800-171 Rev. 2, allowing contractors to prepare before third-party certification becomes mandatory.
• Under 32 CFR 170.3(e), full rollout occurs in four phases over three years — but readiness begins now.

Phase 1: Self-Assessment vs. Certification

During Phase 1, most contractors will perform CMMC Level 1 (FCI) or CMMC Level 2 (CUI) self-assessments, not third-party (C3PAO) certifications.

The DoD’s CMMC FAQs clarify:

• Solicitations will primarily include self-assessment requirements — Level 1 for FCI and Level 2 for CUI.
• Program Managers (PMs) and Contracting Officers may include C3PAO certification only when sufficient qualified vendors exist.
• Contractors should confirm expectations with their Contracting Officer, PM, or Prime Contractor ahead of new solicitations.

This phased rollout gives contractors an opportunity to self-assess, remediate, and prepare for full certification in later phases.

What DoD Contractors Should Be Doing Now

The message is clear: don’t wait until November 10th.

✅ If you’ve completed your self-assessment (NIST 800-171 Gap Assessment) but haven’t begun remediation — start now.
✅ If you’ve submitted your SPRS score, ensure it’s accurate and supported by a current System Security Plan (SSP) and Plan of Action & Milestones (POA&M).
✅ If critical controls like MFA, encryption, or access management aren’t implemented, make them your top priority.

Your Final 30-Day CMMC Readiness Plan

Days 27–20: Validate Your Baseline

• Review your SPRS score for accuracy and confirm NIST SP 800-171 Rev. 2 alignment.
• Verify SSP and network boundary definitions are complete.
• Ensure service providers (MSPs, CSPs, MSSPs) meet FedRAMP Moderate or equivalency if they process or store CUI.

Days 19–10: Close Out POA&Ms

• Prioritize remediation of critical security controls.
• Document progress and update your SSP.

Days 9–1: Affirm Compliance

• Confirm your SPRS submission and final documentation.
• Update your SSP and POA&M to reflect your current posture.
• Be prepared to provide evidence if requested.

Why Waiting Is Risky

Phase 1 is not a grace period — it’s a qualification period. DoD contractors demonstrating measurable progress will remain competitive; those that delay may be excluded from solicitations requiring compliance evidence.

A valid self-assessment requires:

• Implementation of NIST SP 800-171 (110 controls) and 800-171A (320 assessment objectives)
• Submission of a current SPRS score
• A documented SSP and POA&M
• Annual affirmation of compliance

Final Thought: Treat Phase 1 as the Real Test

While CMMC Level 2 (C3PAO) certifications may not be widespread until Phase 2, organizations that remediate and document their controls now will be months ahead when audits begin.

Your countdown to compliance isn’t just about meeting requirements — it’s about maintaining eligibility and protecting your pipeline.

As stated in the Department of Defense’s CMMC FAQs (September 2025): “If you have completed an assessment but have not started remediation — you should get started.”

Why Choose Peerless?

We help defense contractors get audit-ready — from gap assessments and remediation to documentation and evidence preparation. Our teams align your environment to NIST SP 800-171 and positions you for a smooth certification process.

📅 Schedule a CMMC Readiness Consultation