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!

January 27, 2023

There’s Been Another Step Towards Passwordless Authentication

While at the moment, passwords are an important part of your security stack, it is important to acknowledge that the concept of the password was always a flawed system and is overdue to be replaced. This may become a widespread reality sooner than you may expect, too, especially with the buy-in that the big names in tech are demonstrating.

January 26, 2023

4 Communication Strategies that Will Help You Get More Done

Communication is a major part of any relationship. In business, there is no way to have a positive working relationship without great communication. A lot of time and effort goes into getting your employees the tools they need to potentially be successful, but without the right mindset and practices, nothing will go the way you anticipate. Let’s look at four variables that are needed by you and your employees if you want to have crystal clear communications.

January 25, 2023

Different Scams Impact Different Audiences, Which Means You Need to Prepare for All of Them

Back during the holiday season, the Federal Trade Commission shared some data that showed that members of Generation X, Millennials, and Generation Z are all more likely to fall for online shopping scams than those over the age of 60…and not by a little, either. Those under that age are apparently 86 percent more likely to fall for these scams.

Welcome to the First Column IT Tech Blog