Cybersecurity Blog

When Will CMMC 2.0 Be Required for DoD Contracts?

Written by Laura Arce Fonseca | Apr 05, 2025

The Cybersecurity Maturity Model Certification (CMMC) is a Department of Defense framework designed to strengthen cybersecurity across its supply chain. If you’re a DoD contractor, you’ll soon be required to meet CMMC standards to compete for contracts.

This article breaks down the official implementation timeline, outlining exactly when you must comply with CMMC 2.0 at different certification levels. So, when will CMMC 2.0 be required for DoD contracts? 

Key Takeaways

  • CMMC 2.0 will be required for DoD contracts starting October 1, 2025, with full implementation by 2028.
  • Compliance is mandatory for contractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI).
  • Partnering with cybersecurity experts like BEMO can simplify the compliance process.

Table of Contents:

What Is CMMC 2.0?

CMMC 2.0 is the updated Cybersecurity Maturity Model Certification, requiring DoD contractors to implement security controls based on the sensitivity of the information they handle. It protects Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) while streamlining the original model from five levels to three and aligning with NIST SP 800-171.

CMMC 2.0 Levels

  • Level 1 (Foundational): Requires basic cybersecurity practices to protect FCI, with self-assessments.
  • Level 2 (Advanced): For contractors handling CUI, implementing 110 NIST SP 800-171 controls. Self-assessments are required for critical security, while non-critical CUI undergoes triennial third-party assessments.
  • Level 3 (Expert): Reserved for highly sensitive data, building on Level 2 with additional NIST SP 800-172 controls and government-led assessments every three years.

 

CMMC 2.0 Timeline

The Department of Defense is rolling out CMMC 2.0 in phases, with initial requirements set for October 1, 2025. Your business must meet the appropriate certification level by this deadline to remain eligible for DoD contracts. Understanding the timeline will help you plan for compliance and avoid disruptions.

Phase 1

Phase 1 begins in early to mid-2025, once the DoD finalizes the second part of the CMMC rule under 48 C.F.R. Part 204. During this phase, new DoD solicitations will include self-assessment requirements for CMMC Level 1 and Level 2. You won’t need certification yet, but you must self-assess and affirm compliance to bid on contracts.

Phase 2

Phase 2 starts in early to mid-2026, at which point the DoD will begin requiring third-party CMMC Level 2 certification for applicable contracts. If your business handles CUI, you must be certified to remain competitive in the bidding process.

Phase 3

Phase 3 begins in early to mid-2027. If you have a contract awarded after this date, you must obtain CMMC Level 2 certification to exercise option periods. The DoD will also introduce CMMC Level 3 certification for select contracts involving more sensitive data.

Phase 4

Phase 4, launching in early to mid-2028, marks full implementation. At this point, all new solicitations and contract renewals requiring CMMC compliance will enforce certification as a condition of award.

When Will CMMC 2.0 Be Required for DoD Contracts?

To summarize, CMMC 2.0 will be required for DoD contracts starting October 1, 2025. The rollout will occur in phases, with self-assessments beginning in 2025 and full certification requirements phased in through 2028 for applicable contracts.

 

How Does CMMC 2.0 Impact DoD Contractors?

Failing to meet CMMC requirements for DoD contractors can result in losing both current and future contracts, making it essential for your organization to meet the necessary security standards.

For those at Level 2 and Level 3, compliance goes beyond self-assessments. 

Contractors must undergo third-party evaluations conducted by CMMC Third-Party Assessment Organizations or the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) to verify that security measures meet the required standards.

Preparing for CMMC 2.0

To get started, conduct a gap assessment to identify weaknesses in your cybersecurity practices. This allows you to prioritize remediation efforts and allocate resources effectively.

Next, implement the necessary security controls for your CMMC level, which may involve updating policies, deploying new security tools, and training employees on best practices. 

Throughout the process, document your compliance efforts, including security measures and training records, as these will be critical during the assessment phase.

For a smoother transition, consider working with cybersecurity professionals or Managed Security Service Providers who specialize in CMMC compliance. Their expertise can help ensure your organization is fully prepared for certification.

 

What Are the Benefits of CMMC 2.0 Compliance?

CMMC for DoD contractors and subcontractors is essential, offering key advantages that go beyond contract eligibility. Here’s how compliance benefits your business:

  • Ensures Contract Eligibility: Only compliant organizations can bid on and win DoD contracts.
  • Strengthens Cybersecurity: Implementing required security controls protects systems, networks, and sensitive data from cyber threats.
  • Builds Trust and Credibility: Demonstrates your commitment to protecting national security information, fostering stronger relationships with clients and partners.
  • Provides a Competitive Edge: Early adopters of CMMC 2.0 compliance will have an advantage over competitors who are still catching up.
  • Reduces Risk of Cyber Incidents: Strengthening security controls lowers the likelihood of breaches and costly disruptions.
  • Encourages Operational Efficiency: Standardizing security measures streamlines processes, improving overall IT management and compliance readiness.

How Can Businesses Navigate CMMC 2.0 Compliance?

Navigating CMMC 2.0 compliance is challenging, but BEMO streamlines the process with tailored managed services, ensuring your organization meets DoD cybersecurity requirements.

  • Strategic Compliance Planning: BEMO provides a structured roadmap to help your business achieve and maintain CMMC certification.
  • Security Risk Assessments: Identify vulnerabilities and prioritize remediation efforts to align with CMMC controls.
  • Vulnerability Scanning: Detect security weaknesses before they become major threats.
  • Continuous Monitoring: Implement real-time security tracking to detect and respond to cyber risks.
  • Staff Training Programs: Educate employees on CMMC-specific cybersecurity best practices.
  • Ongoing Support & Guidance: Receive expert assistance to maintain compliance as requirements evolve.

Get CMMC 2.0 Ready with BEMO – Stay Compliant, Stay Competitive. 

 

Frequently Asked Questions

What Happens If a Contractor Fails to Meet CMMC 2.0 Requirements?

Non-compliant contractors will be ineligible to bid on or renew DoD contracts that require CMMC certification, potentially resulting in lost business opportunities.

Can Small Businesses Afford CMMC 2.0 Compliance?

Yes, many solutions, such as managed security service providers, offer scalable compliance strategies tailored to small and mid-sized businesses.

Will Existing Contracts Be Affected by CMMC 2.0?

Yes, starting in 2027, contractors must meet certification requirements to exercise option periods on applicable contracts awarded after the rule’s effective date.