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The long-awaited CMMC rollout is finally moving from theory to enforcement. For defense contractors handling Controlled Unclassified Information (CUI), the next three years will determine who stays eligible for Department of Defense (DoD) contracts and who does not. 

Beginning in November 2025, the phased implementation of the Cybersecurity Maturity Model Certification (CMMC) will mark a new era of accountability and cybersecurity maturity across the Defense Industrial Base (DIB). 

Understanding this timeline is critical. Contractors who start preparing now will avoid costly delays, maintain their eligibility, and build trust with both the DoD and prime contractors.

 

Understanding the CMMC Rollout and Why It Matters

CMMC is not simply another compliance framework. It is a structured, phased approach designed to protect sensitive government information throughout the defense supply chain. 

December 2024: The CMMC final rule became effective. 
November 2025: The acquisition rule takes effect, beginning the phased rollout.
By November 2028: Full enforcement will apply to all relevant contracts.

This timeline gives defense contractors an opportunity to align with CMMC requirements before the rules are fully enforced. However, waiting too long to prepare can result in missed opportunities and loss of contract eligibility. CMMC compliance is now a core requirement for doing business with the DoD.

 

The Four Phases of the CMMC Implementation

Each phase builds toward full certification and continuous accountability. Knowing what happens at each stage and how it impacts your organization will help you stay ahead of deadlines. 

Phase 1: Initial Requirements (Starting November 10, 2025)

During the first phase, contractors that handle Federal Contract Information (FCI) or CUI must perform self-assessments for CMMC Level 1 or Level 2. 

Self-attestation remains acceptable for some contracts. 
DoD will begin including CMMC requirements in select solicitations. 
Contractors must publish their scores in the Supplier Performance Risk System (SPRS). 

MAD Security’s Guidance: Begin a NIST 800-171 gap assessment immediately. Identifying deficiencies early allows time to remediate before third-party assessments become mandatory. 

Phase 2: Third-Party Assessments Begin (Starting November 2026)

At this point, CMMC Level 2 certification will be required for contract awards on many projects. 

Third-party assessments by Certified Third-Party Assessor Organizations (C3PAOs) will begin. 
Some contracts may start requiring Level 3 certification. 
Contractors must demonstrate the complete implementation of all 110 NIST 800-171 controls. 

MAD Security’s Guidance: Engage a CMMC Registered Provider Organization (RPO) such as MAD Security to prepare for certification. Our team has successfully guided numerous DoD contractors through CMMC Level 2 certification, helping them build readiness and confidence. 

Phase 3: Level 3 Certification Expands (Starting November 2027)

The DoD will expand Level 3 certification requirements to a broader range of contracts. Cybersecurity expectations will increase significantly. 

Level 2 and Level 3 certifications have become common for new contracts and renewals. 
Contractors must strengthen risk management, incident response, and documentation. 

MAD Security’s Guidance: Enhance your monitoring, incident response plans, and risk management processes to align with NIST SP 800-172 requirements. 

Phase 4: Full Implementation (Starting November 2028)

By this stage, CMMC applies to all new and existing DoD contracts. Contractors who have not achieved certification will lose the eligibility to compete or renew. 

MAD Security’s Guidance: Build sustainable compliance practices. Managed detection and response, continuous monitoring, and regular assessments help ensure certification stays valid throughout the year. 

 

Why You Can’t Wait to Start Compliance

Each phase of CMMC requires time, resources, and verification. Waiting until requirements are enforced will make it nearly impossible to meet certification deadlines without significant disruption. Prime contractors are already asking their subcontractors to demonstrate CMMC readiness. Those who can prove compliance early will gain a clear competitive advantage and secure their place in the DoD supply chain. 

Here are the most important steps organizations should take now: 

Perform a NIST 800-171 gap assessment

 

Perform a NIST 800-171 gap assessment

A gap assessment helps you understand where your current controls fall short and identify the actions needed to achieve compliance. 
Develop a System Security Plan and a Plan of Action and Milestones

Develop a System Security Plan and a Plan of Action and Milestones

Clear documentation shows how your organization meets requirements and outlines the work still needed to close the remaining gaps. 
Partner with a CMMC RPO like MAD Security

Partner with a CMMC RPO like MAD Security

Compliance can be complex, but you do not have to navigate it alone. MAD Security provides expert guidance and practical support to help you move confidently through every phase. 
Maintain continuous monitoring and remediation

Maintain continuous monitoring and remediation

Compliance is not a one-time task. Ongoing monitoring and regular updates are essential to maintaining a strong cybersecurity posture. 

MAD Security Insight: MAD Security has already achieved CMMC Level 2 certification and holds a perfect SPRS score of 110. Our team helps clients reach the same level of preparedness through proven strategies and real-world experience. 

 

How MAD Security Simplifies CMMC Compliance

MAD Security is more than a compliance consultant. As a CMMC Registered Provider Organization (RPO) and CMMC Level 2 Certified Managed Security Services Provider (MSSP), we provide the expertise, experience, and complete solutions defense contractors need to meet CMMC requirements with confidence. 

Our Security Process ensures a structured and repeatable path to readiness: 

Deep Dive Discovery: Identify gaps between people, processes, and technology. 
Solution Design Review: Develop a tailored roadmap that aligns with your security and compliance goals. 
Implementation: Deploy and configure tools, enforce controls, and document evidence. 
Continuous Performance: Monitor, detect, and respond around the clock to maintain compliance and strengthen your security posture. 

With integrated services including SOC as a Service, Virtual Compliance Management, and GRC assessments, MAD Security delivers the most complete solution for defense and government contractors. 

Ready to simplify your CMMC journey and secure your organization’s future? Schedule your consultation with MAD Security today. 

 

Frequently Asked Questions (FAQS)

When does CMMC become mandatory for all DoD contracts?

Full enforcement begins in November 2028. Certification requirements start phasing in as early as November 2025. 

Do subcontractors need certification?

Yes. Prime contractors are already requiring subcontractors to achieve CMMC Level 2 to remain part of the defense supply chain.

What is the difference between self-assessment and certification?

Self-assessments apply to Level 1 and early Level 2 contracts. Third-party certification becomes mandatory for ongoing contract eligibility in later phases. 

What does a CMMC Registered Provider Organization (RPO) do?

An RPO helps contractors prepare for certification by interpreting requirements, identifying gaps, and guiding remediation. Partnering with an RPO like MAD Security ensures your readiness and reduces the risk of audit delays. 

How long does it take to get CMMC certified?

Most organizations need about six to twelve months to reach Level 2 compliance. Starting early with an experienced partner helps avoid delays once certification becomes mandatory. 

 

Original Published Date: November 18, 2025

By: MAD Security