CMMC 2.0 Is Here: Act Now Or Risk Losing DoD Contracts

Key Takeaways:

• CMMC 2.0 requirements can be included in contracts starting November 10, 2025, putting DoD contract eligibility at risk for unprepared contractors and subcontractors.

• Readiness is becoming a strategic advantage as primes demand compliance visibility across their supply chains.

• Acting now enables contractors to identify gaps, implement targeted controls, and maintain momentum ahead of phased CMMC 2.0 deadlines.

The Department of Defense (DoD) phase-in of the Cybersecurity Maturity Model Certification (CMMC) 2.0 program is accelerating, potentially beginning as soon as November 10, 2025. That means your ability to win and keep federal contracts will soon hinge on your cybersecurity readiness.

While large prime contractors and firms have already completed Level 2 certification to avoid delays in their authorization to operate (ATO), many middle-market contractors and subcontractors are behind. Delaying preparation now could mean missed opportunities later — or disqualification from existing or renewal contracts.

CMMC 2.0 readiness is no longer a forward-looking risk mitigation project. It is a near-term business continuity issue. Companies that do not prepare will not just miss new opportunities, they may lose access to current contracts.

Why Readiness Is No Longer Optional

Here's why you need to act now to meet CMMC 2.0 compliance:

1. Enforcement is approaching

CMMC requirements are already appearing in pilot contracts. The DoD has signaled that phased inclusion will begin in late 2025 and continue through 2026. What was once considered a future obligation is now showing up as a prerequisite in solicitations.

The department plans to roll out the program's three-tier model in four phases over the next three years:

• Phase 1 begins on November 10. At that point, solicitations will require CMMC Level 1 or Level 2 self-assessments (where applicable).

• 12 months later, solicitations will require CMMC Level 2 third-party assessments (where applicable).

• Another 12 months after that, solicitations will require CMMC Level 3 assessments — conducted by the Defense Contract Management Agency's Defense Industrial Base Cybersecurity Assessment Center (where applicable).

2. Certification helps protect revenue

Companies that are early movers in CMMC compliance report smoother renewals and fewer delays in project execution. Certification has become a differentiator in the procurement process. Contractors who delay may find themselves locked out of opportunities or unable to meet prime contractor requirements.

3. Readiness drives differentiation

CMMC compliance is becoming a sorting mechanism in defense contracting. Being able to show documented progress, even if not fully certified, can open doors. Waiting to prepare may signal risk to procurement officers. Leading with readiness signals maturity, professionalism, and reliability.

How to Mobilize CMMC 2.0 Readiness

For many organizations in the Defense Industrial Base, the challenge of preparing for CMMC 2.0 is not just about checking compliance boxes; it's about managing operational complexity, competing priorities, and increased scrutiny.

Readiness is not something IT and security teams can solve in isolation — it requires coordination across compliance, leadership, procurement, and finance. Here's how to approach it with clarity and speed:

1. Align your executive team

One of the most common missteps is treating CMMC as a technology project. But it touches every aspect of the business. Your executive team must be aligned on budget, contract risk, internal responsibilities, and timelines.

Organizations that move fastest tend to have direct involvement from the CFO, CIO, and general counsel. Their leadership turns cybersecurity from a reactive compliance burden into a proactive business strategy.

2. Take a smart, lean approach

You don't need to rebuild your entire infrastructure to meet CMMC standards. Start with a scoped readiness assessment focused on what systems interact with controlled unclassified information (CUI) or federal contract information (FCI). Find what documentation already exists, where the real gaps are, and what your specific contract requires.

Build out from there by:

• Creating or updating your system security plan (SSP)

• Prioritizing high-risk controls

• Developing a plan of action and milestones (POA&M) where allowable

• Training employees who handle sensitive data

• Investigate leveraging a scoped enclave solution for necessary processes

This targeted approach helps you move faster without unnecessary cost or complexity.

3. Prepare Your Subcontractors for Compliance

If you are a prime contractor, you handle ensuring subcontractors meet the same CMMC requirements. If your subs handle CUI but are not preparing, your entire contract could be jeopardized.

Readiness means more than managing your own systems. It includes:

• Communicating expectations clearly to subcontractors

• Requiring CMMC alignment in vendor agreements

• Providing resources or support to help partners get ready

• Vetting new vendors for maturity

This is often the weakest link in a contractor's CMMC strategy. Get ahead of it now.

4. Use POA&Ms Strategically

Plans of action and milestones (POA&Ms) can offer breathing room under CMMC 2.0. Some lower-weight controls can be addressed after contract award, but not all. High-impact requirements must still be satisfied before you qualify.

Use POA&Ms as part of your strategy, not your fallback. They can show progress and allow phased implementation, but they are not a substitute for readiness. The DoD will be looking for maturity, not intention.

CMMC Readiness Support from MGO

We help government contractors and supply chain partners prepare for CMMC 2.0 efficiently and strategically. Our advisory services are tailored to your level, timeline, and operational environment.

We support:

• Scoping and level planning

• Gap assessments aligned with NIST SP 800-171

• POA&M and SSP development

• Documentation and remediation planning

• Cybersecurity training and awareness

• Subcontractor readiness coordination

Our team brings extensive experience with DoD frameworks, Defense Federal Acquisition Regulation Supplement (DFARS) requirements, and middle-market risk environments. Whether you are a subcontractor or a prime, we help you clarify your compliance roadmap and move forward with confidence.

Next Steps: Build a Timeline You Can Execute

CMMC readiness does not have to take a year. A focused, well-supported effort can reduce timelines significantly.

Here is a sample 12-week roadmap:

• Week 1: Confirm scope and systems touching CUI or FCI

• Weeks 2 to 4: Perform gap assessment and draft SSP and POA&M

• Weeks 4 to 8: Train staff and remediate priority controls

• Weeks 8 to 12: Complete documentation and verify subcontractor compliance

We also assist clients who are implementing tech-based solutions to solve CMMC Level 2. With our fast-track solution, we can get organizations up and running on fully vetted and compliance enclaves with full CMMC and 800-171 controls managed to adherence in around 6 months. You do not need to be certified tomorrow. But you do need to show momentum and maturity now.

Take Charge of Your CMMC 2.0 Readiness

CMMC 2.0 is not just a cybersecurity update. It is a business imperative. For contractors across the Defense Industrial Base, compliance is becoming the cost of entry.

Waiting could mean lost contracts, blocked renewals, and weakened competitiveness. Readiness, on the other hand, shows leadership and earns trust.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.