Welcome to the First Column IT Tech Blog

HomeBlog
CMMC Phase II Suspension: What it means for your business.

CMMC Phase II Suspension: What it means for your business.

September 10, 2026

The suspension of CMMC Phase II has created a lot of discussion across the Defense Industrial Base, but the practical takeaway for contractors is simpler most people think.

What changed?

Phase II of the CMMC program was slated to take effect in November of this year. Phase II includes requirements on some contracts to achieve CMMC Level 2 certification via C3PAO audit. The Department of War announced an immediate suspension of Phase II requirements while it conducts a review of the program.

What did NOT change?

DFARS 252.204-7012 requirements remain in effect, and contractors are still expected to protect covered defense information. This mandates compliance with NIST SP 800-171 and restricts use of cloud service providers to those that meet the FedRAMP Moderate (Class C) baseline. During this period, the Department stated it will continue enforcing cybersecurity compliance through NIST SP 800-171 self-assessments and selected government-led assessments.

For businesses, this means:

  • You may not need a C3PAO assessment right now.
  • You still need a compliant NIST SP 800-171 environment.
  • You still need a System Security Plan (SSP), documented controls, and evidence that your security program is operating as intended.
  • You still need to use Cloud Service Providers that meet the FedRAMP Moderate (Class C) baseline.
  • Prime contractors and customers will likely continue evaluating cybersecurity maturity when selecting suppliers.

The biggest mistake organizations can make is viewing this suspension as a reason to pause cybersecurity efforts. Whether the future brings a revised CMMC program, a different certification approach, or a return to third-party assessments, the underlying requirement remains the same: Protect sensitive defense information and demonstrate that you're doing it.

Organizations that continue building strong NIST 800-171 programs today will be in a far better position regardless of how the regulatory landscape evolves.

First Column IT is a CMMC Registered Provider Organization (RPO) and we love helping our clients achieve their compliance goals! If your company needs help meeting your DFARS requirements or self-attesting to CMMC, we would love to help you!

Previous Post
January 26, 2024
Here Are Some of the Coolest Tech from CES 2024
January is host to the Consumer Electronics Show, or CES, which takes place in Las Vegas. It’s an opportunity for companies to show off thousands of neat ideas, concepts, and devices, and if you’re a tech nerd like us, it’s total heaven. It’s also interesting to see what trends can be seen and how they might be brought into a business or consumer landscape.
January 24, 2024
Tip of the Week: Quickly Split Text Between Columns in Microsoft Excel
Microsoft Excel is a handy tool to help businesses keep their data organized… provided it has been used accurately and to its full potential. However, it isn’t uncommon for some people to cram all the information of a record into a single cell and limit the value that Excel has to offer. Once this goes on long enough, it can feel like there’s no fixing it.
January 22, 2024
Smartphones Are Great, Until They Are Not
Smartphones are a helpful tool by any measure. Still, with these devices' widespread use, serious concerns about how they may contribute to certain negative human situations have arisen. Here are some ways smartphones can be seen as having a negative effect on people and society. 

Have a project in mind?

Start with our free consultation. We will provide a detailed proposal and firm quote based on your specific IT support needs. All at a predictable monthly cost per seat.
Free Consultation - Sign Up Here