Data, privacy and AI rules

12 due in 60 days · 190 regulations

CMMC 2.0

In force United States (Federal) · In force Dec 16, 2024 · next deadline Nov 10, 2026 (in 14 days)

Deadlines

Coming up
ComplianceNov 10 · in 14 days · Source
Phase 2: Level 2 C3PAO certificationPhase 2 begins one calendar year after Phase 1; applicable solicitations require CMMC Level 2 third-party (C3PAO) certification (32 CFR 170.3(e)(2)).
ComplianceNov 10, 2027 · in 12 months · Source
Phase 3: Level 3 certificationPhase 3 begins one year after Phase 2; Level 3 (DIBCAC) requirements added to applicable solicitations (32 CFR 170.3(e)(3)).
ComplianceNov 10, 2028 · in 2 years · Source
Phase 4: full implementationCMMC requirements included in all applicable DoD solicitations and contracts, including option periods (32 CFR 170.3(e)(4)).
Already passed
Takes effectNov 10, 2025 · 12 months ago · Source
DFARS rule effective; Phase 1 beginsCMMC Level 1 and Level 2 self-assessment requirements begin appearing in applicable DoD solicitations and contracts (32 CFR 170.3(e)(1)).
Takes effectDec 16, 2024 · 22 months ago · Source
CMMC Program rule (32 CFR Part 170) effectiveThe program rule establishing CMMC levels and assessment processes took effect; contract enforcement awaited the DFARS rule.

Summaries for reference, not legal advice. Check the official text.

What it does

Requires defense contractors and subcontractors that handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) to meet a specified CMMC level (Level 1 self-assessment, Level 2 self- or third-party (C3PAO) assessment against NIST SP 800-171, Level 3 DIBCAC assessment against selected NIST SP 800-172 controls) as a condition of contract award. Requirements are phased into DoD solicitations over four years.

Who it applies to
DoD prime contractors and subcontractors at all tiers whose information systems process, store or transmit FCI or CUI in contract performance; excludes contracts solely for commercially available off-the-shelf (COTS) items.
Penalties
Ineligibility for award or option exercise; misrepresented affirmations can create False Claims Act and contractual liability.
Enforced by
U.S. Department of Defense (DoD CIO, contracting officers, DCMA DIBCAC); Cyber AB accredits C3PAOs
Official name
Cybersecurity Maturity Model Certification (CMMC) Program (32 CFR Part 170) and DFARS acquisition rule (48 CFR Parts 204, 212, 217, 252)
Citation
32 CFR Part 170 (89 FR 83092, Oct. 15, 2024); DFARS Case 2019-D041, 90 FR 43560 (Sept. 10, 2025)
Topics
Cybersecurity
Verified 2026-09-22 federalregister.gov dodcio.defense.gov
Research notes

Phase dates computed per 32 CFR 170.3(e): Phase 1 starts on the later of the Part 170 or the 48 CFR rule effective date (November 10, 2025), each later phase one calendar year after the previous; DoD may include higher requirements earlier at its discretion. The DoD CIO site could not be fetched during verification.

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Questions about CMMC 2.0
What are the CMMC 2.0 compliance deadlines?
Dec 16, 2024: CMMC Program rule (32 CFR Part 170) effective. Nov 10, 2025: DFARS rule effective; Phase 1 begins. Nov 10, 2026: Phase 2: Level 2 C3PAO certification. Nov 10, 2027: Phase 3: Level 3 certification. Nov 10, 2028: Phase 4: full implementation.
When does CMMC 2.0 take effect?
CMMC 2.0 took effect on Dec 16, 2024. The next milestone is Nov 10, 2026: Phase 2: Level 2 C3PAO certification.
Who does CMMC 2.0 apply to?
DoD prime contractors and subcontractors at all tiers whose information systems process, store or transmit FCI or CUI in contract performance; excludes contracts solely for commercially available off-the-shelf (COTS) items.
What are the penalties under CMMC 2.0?
Ineligibility for award or option exercise; misrepresented affirmations can create False Claims Act and contractual liability.