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The official dates that matter most
DoD began incorporating CMMC assessment requirements into applicable procurements on November 10, 2025, when DFARS clause 252.204-7021 became effective.
On July 13, 2026, the Department suspended Phase II implementation requirements and paused CMMC implementation in Phase I. The former November 10, 2026 Phase II start date and later rollout dates are no longer current deadlines. No replacement schedule has been announced.
What each phase means
| Phase | Date | Operational meaning |
|---|---|---|
| Phase I | Began 11/10/2025; currently paused | The current official page says Phase I may require Level 1 and Level 2 self-assessments. These requirements and affirmations remain in place. |
| Phase II | Suspended 07/13/2026 | The former 11/10/2026 start date is no longer current, and no replacement date has been announced. |
| Later phases | Schedule under review | The Department is conducting a comprehensive CMMC review. Former Phase III and full-implementation dates should not be used as current deadlines. |
New contracts vs older contracts
The CMMC 101 briefing says the revised DFARS clause took effect on November 10, 2025 for new contracts. If CMMC requirements are to be added to older contracts, that requires a bilateral modification.
That is an important operational point because many companies assume the new rule automatically rewrites their entire existing backlog. It does not. But it can absolutely affect new awards, options, re-competes, and modified work going forward.
When to start if you are not ready
Start before the RFP. The rule structure makes current status relevant at the time of award, and the underlying work for scope, remediation, documentation, and evidence usually takes longer than leadership expects.
A realistic planning posture is to assume that if a customer or prime is already asking questions, the company should already be doing scoping and readiness work rather than waiting for a formal assessment booking.
What this means for planning and award timing
The timeline matters because current CMMC status can determine whether you are eligible for award when a solicitation lands. Contractors that still need scoping, remediation, documentation, or SPRS cleanup should plan backward from anticipated bid dates instead of waiting for procurement language to force a scramble.
Frequently asked questions
When did CMMC start showing up in contracts?
DoD began incorporating CMMC assessment requirements into applicable procurements on November 10, 2025.
What phase is CMMC in right now?
CMMC implementation is paused in Phase I. Phase I self-assessment requirements remain in place, and no Phase I end date has been announced.
When does Phase II begin?
Phase II implementation requirements were suspended on July 13, 2026. No replacement start date has been announced.
When does full CMMC implementation begin?
The former full-implementation calendar is no longer current. The Department is reviewing CMMC and has not announced a replacement schedule.
Do old contracts automatically change because the rule changed?
No. The CMMC 101 briefing says incorporating the clause into older contracts requires a bilateral modification.
What assessments can Phase I require now?
The current official page says Phase I may require Level 1 and Level 2 self-assessments. Verify any different contract-specific direction with the contracting officer.
Should we wait until we see the RFP?
No. Current status matters at award, and scoping, remediation, and evidence work take time.
How long does a CMMC project take?
The government does not publish a single official timeline. Duration depends on scope, current maturity, architecture decisions, documentation quality, and remediation volume.
Related articles
Official sources reviewed
Use this guide to plan readiness and communicate clearly with buyers, primes, and internal stakeholders. Contract language, current regulations, and assessor guidance control.
Want help turning this into a real readiness plan?
Velocity CMMC can scope the environment, map CUI flows, organize the documentation package, support remediation, and help your team prepare for the right assessment path without pretending to be the certifier.