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United States · Cyber

CMMC: cyber certification for DoD contractors

Phasing in.

Randeep Bubbra | Lawyer | Making defence financeable

The Cybersecurity Maturity Model Certification programme (32 CFR Part 170) is being written into DoD solicitations and contracts in four annual phases. Phase 1 began on 10 November 2025, when the DFARS acquisition rule took effect, and Phase 2 begins one year later, adding third-party (C3PAO) Level 2 certification as a condition of award.

Status
Phasing in
Jurisdiction
United States
Area
Cyber
Last reviewed at source
28 Oct 2026
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Official documents

Dates

  • 10 Nov 2026 CMMC Phase 2 begins: Level 2 (C3PAO) certification for applicable DoD contracts
  • 10 Nov 2027 CMMC Phase 3 begins
  • 10 Nov 2028 CMMC Phase 4 (full implementation) begins

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General information as at the review date, not legal advice. Each document links to its official source.