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
June 5, 2026
If Your Team Resists New Technology, Here’s How to Win the Battle of Adoption
When was the last time you consulted your team members about a planned technology change or investment? Never, right? Instead, you look at the metrics, balance the various return on investment figures, and determine whether to invest in a new platform.
June 3, 2026
Why Optional Updates Are Actually Mandatory for Your Safety
Chances are you’ve seen the update window out of the corner of your eye while you’re going about your day-to-day tasks. For most employees, the choice is easy. They can click “Remind me later” to make today’s problem tomorrow’s. This creates a patch gap, which inadvertently becomes a major security hole for your small business.
June 1, 2026
The Modern AUP Protects Data and Empowers Teams
Many technology policies are outdated documents filled with legal prohibitions. Employees often sign these forms during their first day of work and never look at them again. This approach is ineffective because overly restrictive rules lead staff to use unapproved software just to complete their tasks. This behavior creates security risks that are difficult to monitor or manage.

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