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
February 18, 2026
5 IT Mistakes That Reset Your Progress (And Your Profits)
Did you know that industry data suggests that the average small business loses over $10,000 per year simply by making “common-sense” IT decisions that lack a long-term strategy? In fact, most IT decision-makers look at technology as little more than a utility, like water or electricity, rather than a competitive advantage. IT is not a cost to be minimized; it’s a way to get ahead (and stay ahead), and it’s time to fix the mistakes you’ve made in the past.
February 16, 2026
Three Disasters That Could Shut Down Your Business
What is the actual price tag of a worst-case scenario? Most business owners view IT as a safety net, something that only needs to be there to catch them when things break. But here is the cold, hard truth: If you are waiting for the crash to happen before you take action, you have already lost.
February 13, 2026
Why Your Business Needs an IT Roadmap Today
Let me pose a (hopefully) hypothetical scenario: your business has relied on your server since 2019. Each and every day, it handles every request that your business has had of it, but on an otherwise uneventful Tuesday, it suddenly conks out, dead as a doornail. So, what do you do?

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