CMMC After the Phase 2 Suspension

The November 10, 2026 deadline was suspended. Your contract obligations were not. A plain-English plan for small defense subcontractors.

By Cytronics/Published

  • ///What stopped, what still applies, and what could change next
  • ///How to find out which CMMC level your subcontract really needs
  • ///A fillable contract inventory, score tracker and 60-day plan
Get the 8-page PDF
July 13, 2026

Date the suspension of CMMC Phase 2 was announced, with a 60-day review to follow

$507,144

What a Huntsville, Alabama contractor agreed to pay in 2026 to resolve False Claims Act allegations about NIST SP 800-171 (allegations only)

-170

The score that contractor received when the government assessed it, on a range of -203 to 110

Plenty of advice is still counting down to a deadline that was suspended

Search for CMMC today and you'll still find pages telling you to book a third-party assessment before November 10, 2026. On July 13, 2026, the Department of War suspended that requirement and started a review. That's good news for your budget, but it isn't permission to stop.

The older rules in your contracts still apply, and a score you post can still be challenged. This program is under active review, so check the latest clause in your own contract before you spend money.

What stopped and what didn't

ItemStatus
Level 2 third-party (C3PAO) assessment as a default on November 10, 2026Suspended
Level 3 assessments by the governmentSuspended
Level 2 (C3PAO) or Level 3 language already in a contractBeing removed by contract changes
Level 1 (Self) and Level 2 (Self), with SPRS scores and annual affirmationsStill in place
DFARS 252.204-7012: NIST SP 800-171, 72-hour incident reporting, cloud rulesStill in place
FAR 52.204-21: 15 basic safeguards for federal contract informationStill in place

Three things to do this month

  • ///
    Ask each prime in writing what you'll handle

    Confirm whether you'll receive CUI or only federal contract information, and which CMMC level they now require. Keep the reply.

  • ///
    Get the DoD medium assurance certificate now

    You need it to report a cyber incident at all, and the 72-hour clock in DFARS 252.204-7012 was never suspended.

  • ///
    Score yourself honestly before you post anything

    A low, accurate score is a to-do list. A high, false one can become a False Claims Act problem.

How an attacker sees it

A suspended deadline changes nothing about who wants your data. Small suppliers often hold the same drawings as the prime, behind far less security. We'd look for you first, whatever the assessment calendar says.

What's in the full PDF

  • ///A table showing how your level follows from what you handle and what the prime requires
  • ///How to shrink what's in scope, and the Microsoft 365 cloud question
  • ///The scoring rules that matter, with a fillable score tracker
  • ///A 72-hour incident checklist and a week-by-week 60-day plan