How Will the Department Implement CMMC and How Can Businesses Prepare?

The Four-Phase CMMC Implementation

The DoD is rolling out CMMC gradually to give the defense industrial base time to prepare. Here's the complete timeline:

Phase 1: November 2025 - November 2026

Self-assessment requirements in applicable solicitations. Level 1 and Level 2 self-assessments begin. This is the current phase.

Phase 2: November 2026 - November 2027

Level 2 C3PAO (third-party) assessments begin for contracts requiring independent verification of CUI protection.

Phase 3: November 2027 - November 2028

Level 3 DIBCAC-led assessments begin for the most sensitive programs.

Phase 4: November 2028+

Full implementation across all applicable DoD solicitations and contracts.

How to Prepare Now

1. Conduct a gap assessment — Compare your current controls against NIST SP 800-171 Rev 2
2. Develop your SSP — Document how each of the 110 requirements is implemented
3. Enter your score in SPRS — Required for Phase 1 self-assessments
4. Remediate gaps — Prioritize critical requirements that can't be on a POA&M
5. Engage a C3PAO — If you need Level 2 independent assessment, schedule early

Don't wait for your specific phase — C3PAO availability will be limited as demand surges. Early movers gain a competitive advantage in contract competitions.