By Payam Pourkhomami, President & CEO of OSIbeyond
The clock is ticking for defense industrial base contractors because the Department of Defense begins enforcing Cybersecurity Maturity Model Certification requirements across new solicitations and contracts on November 10.
For the estimated 80,000 contractors handling controlled unclassified information, a.k.a. CUI, CMMC is a business-critical requirement because no certification means no contract awards. Even existing contracts won’t provide a safe harbor, as option periods and renewals will demand all requirements to be met, documented and validated through formal assessment.
With nearly half of defense contractors reporting inadequate preparation and only 26 managed service providers nationally achieving Level 2 certification (as of the time of this article), the path to compliance requires immediate action. This article provides defense contractors with actionable intelligence on the finalized CMMC requirements and outlines the concrete steps you must take effective Nov. 10 to protect your ability to win and maintain DOD contracts.
What’s in the CMMC Final Rule Update?
The DOD’s final implementation framework for CMMC reached a milestone when the 48 CFR Acquisition Rule cleared regulatory review on Aug. 29. Following its publication in the Federal Register on Sept. 10, the 60-day countdown to enforcement began.
The DOD structured CMMC implementation across four distinct phases over three years, each building upon the previous to achieve full compliance across the DIB by November 2028:
- Phase 1 (Nov. 10) introduces CMMC as a condition of contract award for applicable DOD solicitations. During this initial year, contractors must complete and submit self-assessments to the Supplier Performance Risk System, or SPRS, before contract award. Organizations handling federal contract information, a.k.a. FCI, will self-assess against 17 basic safeguarding requirements for Level 1, while those managing CUI must demonstrate compliance with all 110 NIST SP 800-171 controls for Level 2.
- Phase 2 (Nov. 2026) escalates requirements significantly by making C3PAO certification mandatory for new contracts involving CUI. While self-assessments continue for Level 1 requirements (and in very small subset of contracts for Level 2 requirements) any contractor handling CUI must obtain third-party certification as a condition of award. The department may allow certain contractors to defer certification until contract option periods, but this represents an exception rather than the rule.
- Phase 3 (Nov. 2027) extends certification requirements to contract renewals and introduces Level 3 assessments for programs with heightened cybersecurity needs. Organizations that secured contracts during Phase 1 under self-assessment must now achieve full certification to exercise option periods. This phase effectively closes the compliance loop by preventing contractors from indefinitely deferring certification through existing contract vehicles.
- Phase 4 (Nov. 2028) marks full implementation across the DIB. Every applicable DOD solicitation and contract involving FCI or CUI will require appropriate CMMC certification, including option periods on legacy contracts predating the program. According to DOD estimates in the Federal Register, almost all companies needing CMMC will require either Level 1 or Level 2 certification, with Level 3 remaining relatively rare for only the most sensitive programs.
Prime contractors face additional complexity, as they must flow down CMMC requirements throughout their supply chain to make sure every subcontractor meets the same certification level for their portion of work involving covered information. The cascading obligation creates a domino effect where a single non-compliant supplier can jeopardize an entire contract and force primes to reassess vendor relationships and potentially restructure long-standing supply chains.
How to Prepare for CMMC Implementation
Because the implementation of CMMC requirements is beginning soon, organizations must move beyond theoretical preparation into concrete action.
Assess Your Compliance Readiness
Before pursuing CMMC certification, every defense contractor must conduct an honest evaluation of their current cybersecurity posture against the required controls to reveal gaps between existing practices and CMMC requirements. To help organizations understand the scope of work ahead, OSIbeyond offers a CMMC Prerequisite Checklist that outlines the essential information and documentation you’ll need to gather before beginning formal compliance efforts.
While the temptation may exist to treat this as a standard IT project, CMMC compliance demands a fundamentally different approach that combines technical implementation with the interpretation of dense regulatory language, the mapping of controls to specific implementations, the production of audit-ready documentation and the understanding of how assessors evaluate evidence. Because compliance-focused skills fall outside typical IT responsibilities, internal IT personnel often struggle with the implementation of CMMC requirements.
For these reasons, partnering with a qualified managed service provider, or MSP, is greatly beneficial for successful CMMC compliance. MSPs specializing in defense contractor requirements bring the unique combination of technical expertise and compliance knowledge that internal teams rarely possess. They understand how to translate NIST SP 800-171 controls into practical implementations, maintain the extensive documentation assessors expect, and avoid the common pitfalls that lead to assessment failures.
Find the Right MSP Partner
Your choice of MSP will significantly impact your CMMC assessment outcome. While MSPs aren’t required to obtain their own CMMC certification, they do fall directly within your assessment scope as external service providers, so assessors will scrutinize their security practices, documentation and controls as part of your evaluation. MSPs not already invested in the DIB by Q4 2025 are unlikely to meet your CMMC needs. If they haven’t begun their own compliance journey, they lack the practical experience and technical infrastructure necessary to guide you through assessment.
On the other hand, a certified MSP is guaranteed to simplify your path to compliance through validated controls and proven documentation. The only problem is that there are currently only 26 MSPs and MSSPs nationally (as of the time of this article) that have achieved Level 2 certification. The low number reflects both the significant investment required (typically $100,000-$200,000+) and the extensive commitment needed to meet all 110 NIST SP 800-171 controls.
The MSP Collective directory serves as your primary vetting resource for identifying qualified providers. Founded by Summit7, a leader in the CMMC space, this non-profit initiative maintains the only validated directory of certified external service providers. Every MSP listed has achieved Level 2 certification (verified with the C3PAO that assessed them) and are considered as leading providers in the CMMC market.
Here’s how you can use the MSP Collective directory to secure qualified support:
- Check your current MSP’s certification status by visiting the MSP Collective directory and searching for your provider. If they appear on the list, you have confirmation of their Level 2 certification and can proceed with confidence in their ability to support your compliance journey.
- Verify credentials independently if your MSP isn’t listed in the directory. Request their C3PAO certificate directly. Be cautious of providers who claim to be “in process” or “planning to certify” as any provider who is not compliant by now is not a serious contender in the CMMC market.
- Research two to three certified alternatives from the directory if your current MSP lacks certification, and initiate conversations with those providers. With only 26 certified providers nationally (as of the time of this article), competition for their services will intensify as CMMC Phase 2 implementation rolls out.
Once you have found the right MSP partner, the path to CMMC compliance becomes significantly clearer.
The Nov. 10 Deadline Demands Action Today
With CMMC enforcement beginning Nov. 10, the window for preparation is closing. Organizations that haven’t started their compliance journey face an uncomfortable reality of a six to 12-month implementation timeline. Every day of delay increases the risk of losing contract award eligibility when Phase 1 requirements take effect.
Furthermore, as of the publication of this article, there are 81 Certified 3rd Party Assessor Organizations, or C3PAOs, 355 Registered Provider Organizations, or RPOs and 525 CMMC Certified Assessors, or CCAs, officially listed on the CyberAB CMMC marketplace. According to Department of Defense estimates, 337,968 unique entities, including both prime and subcontractors, will be impacted by CMMC requirements.
It is evident that the number of CMMC assessors and providers is disproportionate to the total number of entities that must meet CMMC requirements. This situation is expected to create a significant industry bottleneck; indeed, some C3PAOs are already booked a year in advance. Therefore, it is crucial for contractors to begin their CMMC compliance preparation immediately to stay ahead of the inevitable bottleneck.
The most efficient and effective path to CMMC compliance is to partner with CMMC experts who can facilitate the entire process within a reasonable timeframe, typically taking six to 12 months for Level 2 certification. Attempting to achieve CMMC compliance as a do-it-yourself project risks significant delays or potential failure in a formal assessment if any control requirements are not met according to the assessor’s observations. This could be a costly mistake for companies aiming to remain competitive in the defense contracting sector.
Contact OSIbeyond today for a CMMC readiness consultation and discover how partnering with a certified MSP transforms compliance from a looming threat into a competitive advantage. Your DOD contracts depend on the decisions you make now.
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