As of November 10, 2025, the U.S. Department of Defense (DoD) has officially started enforcing the Cybersecurity Maturity Model Certification (CMMC) rule.
This milestone marks the beginning of a phased rollout requiring DoD contractors and subcontractors to demonstrate compliance at the appropriate CMMC level.
In other words, compliance is no longer optional — it’s now a condition of doing business with the DoD.
What’s Changed Under CMMC 2.0
- CMMC clauses are now active. Contracting officers can include CMMC level requirements in new solicitations and awards.
- Compliance must be maintained. Contractors must keep a current CMMC status for the duration of their contract.
- Subcontractor flow-downs apply. If you’re a prime, you must ensure subs handling FCI (Federal Contract Information) or CUI (Controlled Unclassified Information) are compliant.
- Waivers are rare. The DoD has made clear that waiting until the solicitation arrives is a risky strategy. Few waivers will be approved.
Why So Many Contractors Still Aren’t Ready
Even after years of preparation, readiness gaps remain across the defense industrial base, particularly among small and mid-sized firms. Common challenges include:
- Uncertainty around which CMMC level applies (Level 1, Level 2 Self-Assessment, Level 2 C3PAO, or Level 3)
- Incomplete System Security Plans (SSP) or Plan of Action & Milestones (POA&M)
- Inconsistent mapping of existing controls to NIST SP 800-171 requirements
- Overlooking subcontractor compliance responsibilities
- Underestimating the time and effort needed for remediation and assessment
Bottom line: “Almost ready” isn’t ready enough. The DoD now requires demonstrable compliance, documented, auditable, and sustained.
7 Steps to Strengthen Your CMMC Readiness
- Define your scope – Identify which systems store or process FCI or CUI.
- Determine your required level – Review contracts and solicitations to see what’s mandated.
- Conduct a gap analysis – Compare your current cybersecurity posture against CMMC controls.
- Update your SSP and POA&M – Document what’s done, what’s planned, and by when.
- Plan your assessment path – Whether it’s a self-assessment or a C3PAO audit, book early.
- Check subcontractors – Ensure flow-down obligations are met and verified.
- Track and maintain – Compliance isn’t a one-time project. It’s an ongoing requirement.
How SME, Inc. Can Help
SME, Inc. is a Cyber AB Registered Provider Organization (RPO) helping defense contractors navigate CMMC requirements confidently and efficiently.
We provide:
- Expert-led gap analysis and remediation planning
- Dedicated compliance engineers
- Support for SSP and POA&M development
- Compliance dashboards for tracking progress and reporting
- Subcontractor readiness management
- Preparation for third-party (C3PAO) or self-assessments
Let us help you close the gaps before your next DoD opportunity.
Schedule your free consultation today
Frequently Asked Questions (FAQs)
1. What is the CMMC rule that went into effect on November 10, 2025?
The DoD’s final CMMC 2.0 rule, codified in DFARS and Title 48 CFR, formally requires defense contractors to meet and maintain the cybersecurity maturity level specified in their contract. This rule integrates CMMC directly into the DoD acquisition process.
2. Who needs to comply with CMMC?
Any organization in the DoD supply chain that processes, stores, or transmits Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) must comply. This includes both prime contractors and their subcontractors.
3. What are the three levels of CMMC?
- Level 1: Basic safeguarding for FCI.
- Level 2: Advanced safeguarding for CUI (aligned with NIST SP 800-171).
- Level 3: Expert level for highest-risk environments (aligned with NIST SP 800-172).
4. How long does it take to become CMMC compliant?
The timeline varies based on your current cybersecurity maturity and required level. Most organizations take 6–12 months from initial gap assessment to certification readiness.
5. What happens if I’m not compliant when the DoD requests proof?
Failure to demonstrate compliance may result in ineligibility for new contracts or contract renewals, and potential liability under the False Claims Act if noncompliance is misrepresented.
Final Thoughts
CMMC enforcement is here. The first phase of compliance has already begun, and contractors who delay risk losing competitive ground.
By partnering with SME, Inc., you can identify your gaps, strengthen your systems, and position your organization for ongoing success in the DoD supply chain.
