CMMC After the Phase 2 Suspension: What Contractors Still Have to Do in 2026

By CyberExperts Editorial Team   Published: 11/02/26   10 min read

Short answer: on July 13, 2026, the Department of War suspended the move to CMMC Phase 2, which was due on November 10, 2026. Phase 1 did not go away. Contractors still need a CMMC Level 1 or Level 2 self-assessment where a contract calls for one, their results and score in SPRS, and an annual affirmation from a senior official. Safeguarding and incident-reporting duties under DFARS 252.204-7012 also continue.

Last checked: November 2, 2026. This guide is free, has no sign-up, and every rule below is tied to an official source listed at the end. It is general information, not legal advice. Your contract and your contracting officer decide what applies to you.

What happened on July 13, 2026

The Department of War announced the immediate suspension of the Phase 2 requirements that were scheduled to begin on November 10, 2026. Its news release says all Phase 1 self-assessment requirements remain in place and that a review of the whole program is under way, led by a CMMC Reform Task Force with a 60-day timeline. The same day, the Under Secretary of War for Acquisition and Sustainment issued implementing memorandum 26-P-1023.

The memo says that during the suspension, program offices may only ask for CMMC Level 1 (Self) or Level 2 (Self). They may not designate Level 2 (C3PAO) or Level 3 (DIBCAC) assessments. Active solicitations that asked for those levels must be amended, and existing contracts must have them removed by modification before the next option is exercised or at the next scheduled administrative modification. The memo also says no waivers will be granted during the review.

DateEventSource
December 16, 2024CMMC program rule (32 CFR part 170) takes effect89 FR 83092
November 10, 2025DFARS rule for CMMC contract clauses takes effect, starting Phase 190 FR 43560
July 13, 2026Phase 2 suspended; memo 26-P-1023 issuedDoD CIO CMMC page and memo 26-P-1023
July 16, 2026Class Deviation 2026-O0025, Revision 2 issued (later superseded)Revision 3 memo
September 3, 2026Class Deviation 2026-O0025, Revision 3 carries the suspension into contracting rulesRevision 3 memo
November 10, 2026Original Phase 2 start date, now suspendedRelease and memo above
Phase 1 began when the DFARS rule took effect, and Phase 2 was set to begin one calendar year later under 32 CFR 170.3(e).

What is paused and what still applies

Paused during the suspensionStill in force
The November 2026 move to Phase 2Phase 1 self-assessment requirements
Requiring Level 2 (C3PAO) third-party certification in new solicitationsLevel 1 (Self) and Level 2 (Self) as contract requirements
Requiring Level 3 (DIBCAC) assessmentsEntering results in SPRS and filing affirmations
Pending and future implementation milestonesNIST SP 800-171 Revision 2 compliance under DFARS 252.204-7012
Waiver procedures72-hour cyber incident reporting to DoD

The suspension is a policy decision, not a rewrite of the regulation. The eCFR text of 32 CFR 170.3 we read (issue date October 29, 2026) still describes the four phases. The September 3 class deviation tells contracting officers to follow the suspension, and it keeps the rule that they check SPRS before award and before exercising an option.

Phase 1 self-assessments

Level 1 (Self)

Level 1 covers Federal Contract Information and the basic safeguarding requirements of FAR 52.204-21. Under 32 CFR 170.15:

Level 2 (Self)

Level 2 covers Controlled Unclassified Information and maps to NIST SP 800-171 Revision 2, which has 110 requirements. Under 32 CFR 170.16 and 170.21:

Your SPRS score

SPRS is the Supplier Performance Risk System. It stores results; it does not perform the assessment. To enter results, your company needs a PIEE account with the SPRS Cyber Vendor User role, according to the SPRS NIST SP 800-171 page.

The score starts at 110, the number of NIST SP 800-171 Revision 2 requirements. For each requirement that is not fully met, you subtract its value. The DoD Assessment Methodology and 32 CFR 170.24 give each requirement a value:

Points subtractedWhat the requirement doesExamples
5Failure could allow significant exploitation of the network or loss of CUI3.1.1 limit system access, 3.5.1 and 3.5.2 identify and authenticate users, 3.6.1 incident handling, 3.14.1 flaw remediation
3Failure has a specific, confined effect3.1.5 least privilege, 3.3.2 traceable user actions, 3.8.1 protect media, 3.11.1 periodic risk assessment
1Failure has a limited or indirect effectMost remaining derived requirements
3 or 5Partly effective implementations3.5.3 multifactor authentication: 3 off if only for remote and privileged users, 5 off if not used. 3.13.11 FIPS-validated cryptography: 3 off if encryption is not FIPS-validated, 5 off if none.
Source: NIST SP 800-171 DoD Assessment Methodology Version 1.2.1 and 32 CFR 170.24.

Annual affirmations

An affirming official is a senior representative of your company who is responsible for CMMC compliance and has authority to affirm it. 32 CFR 170.22 says the official must submit an affirmation in SPRS:

Each affirmation names the official, with title and contact details, and states that your company has implemented and will maintain all applicable requirements for its status across the systems in scope.

Affirmations keep a status current. In the revised DFARS text issued with the class deviation, a Final Level 1 (Self) status counts as current for one year, a Final Level 2 (Self) status for three years, and in both cases the affirmation can be no more than one year old. A Conditional status counts as current for 180 days.

What stays the same under DFARS 252.204-7012

The memo says the cybersecurity requirements in DFARS 252.204-7012 remain in effect, and the Department says it will enforce NIST SP 800-171 Revision 2 through self-assessments and select government-led assessments during the suspension. The clause requires adequate security on covered contractor information systems and reporting of cyber incidents within 72 hours of discovery. The DoD news release adds that the action does not remove the duty to protect federal data.

A practical checklist

  1. Read the CMMC level and clauses in each solicitation and contract. Contracts and amendments may change during the suspension.
  2. List every system that handles Federal Contract Information or CUI, and write down the scope.
  3. Complete the Level 1 self-assessment if you handle FCI, or the Level 2 self-assessment if you handle CUI. Score it honestly using the 110-point method.
  4. Write or update the system security plan and a POA&M for any gaps.
  5. Enter results in SPRS through PIEE and have the affirming official file the affirmation.
  6. Put the annual affirmation, the three-year Level 2 reassessment and the 180-day POA&M deadline on a calendar.
  7. Keep the assessment evidence for six years.
  8. Check the DoD CIO CMMC page and your contracting officer before any decision that assumes Phase 2 will or will not return.

What we could not verify

FAQ

Is CMMC still required after the Phase 2 suspension?

Yes, where a contract includes a CMMC requirement. Phase 1 stays in place, so a contract can still require a Level 1 (Self) or Level 2 (Self) status. What is paused is the move to third-party Level 2 certification and Level 3 assessments.

What exactly was suspended on July 13, 2026?

The Department of War suspended the transition to Phase 2, scheduled for November 10, 2026, along with pending and future CMMC implementation milestones. Program offices may only designate Level 1 (Self) or Level 2 (Self) during the suspension.

Do I still need to post a score in SPRS?

If your contract or solicitation requires a Level 2 (Self) status, yes. The overall score, such as 105 out of 110, goes into SPRS. A Level 1 (Self) entry records a compliance result instead of a score.

How often is the affirmation due?

At the completion of each assessment, after any POA&M closeout, and every year after the Final status date. A senior official files it in SPRS.

Can I use a POA&M for Level 1?

No. Level 1 allows no POA&M. Level 2 (Self) allows one only for limited requirements, and only if your score is at least 88 of 110.

Does the suspension change NIST SP 800-171 or incident reporting?

No. DFARS 252.204-7012 remains in effect, including NIST SP 800-171 Revision 2 and reporting cyber incidents within 72 hours.

Will Phase 2 come back?

We could not find an official decision. The Department said it would issue further guidance after its review. Watch the DoD CIO CMMC page.

Sources

Related reading: Cybersecurity laws and regulations in 2026 and DoD 8140 approved certifications.

CyberExperts Editorial Team

CyberExperts guides are researched from official certification body sources and fact-checked by the CyberExperts editorial team.