Phase 1: Early to Mid-2025
- DoD finalizes the second part of its CMMC rule under 48 C.F.R. Part 204.
- New DoD solicitations require self-assessments for CMMC Level 1 and Level 2 compliance.
- Prime contractors ‘may’ require downstream (subcontractor) DIB companies CMMC Level 2 C3PAO certifications in lieu of self-assessment.
Phase 2: Early to Mid-2026
- DoD includes CMMC Level 2 certifications in applicable solicitations.
- Contractors bidding on these opportunities must achieve Level 2 certification by this time.
Phase 3: Early to Mid-2027
- CMMC Level 2 certifications become mandatory to exercise option periods on applicable contracts awarded post-rule.
- DoD introduces CMMC Level 3 certification requirements in select solicitations.
Phase 4: Early to Mid-2028
- CMMC requirements apply to all applicable solicitations and contract option periods, regardless of award date.