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
October 10, 2025
A Small Business Owner's Guide to Understanding and Preventing Ransomware
How much would you be willing to pay to keep all of your business’ records from being locked away, or to keep them off the dark web? Hundreds? Thousands? More?
October 8, 2025
The Absolute Basics of Data Backup
How much data do you think your business stores? How much of that data does your business need to operate? Regardless of your answers to these questions, one thing is for certain: you need to take action to ensure your business’ data is never put in harm’s way needlessly. It should be able to survive in the face of great adversity, whether it’s from a fire, weather incident, cyberattack, or simple user error.
October 6, 2025
3 Ways the Right Technology Can Fuel Your Company’s Success
You want your company’s technology to aid your employees in getting their work done, not hinder their ability to be productive. This might seem like a logical statement, but you’d be surprised by how many businesses struggle with implementing the right technology for the right job. If you want to increase employee morale, build a better company culture, and boost productivity, your company should consider the following technologies for the employee experience.

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