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
August 1, 2025
Tip of the Week: Minimize All
How often do you find yourself overwhelmed by the sheer amount of clutter on your desktop? You might dig through a pile of applications, windows, files, and so much more, and it can be difficult to make sense of it all and be productive. Thankfully, there is a rather simple tool to help you clean up your desktop and focus on one window at a time.
July 30, 2025
Why Double and Triple-Extortion Are So Scary
Ransomware is bad, and you can’t take any chances with it if you want to keep your business safe. Understand that it might seem like we’re exaggerating, but we’re not; ransomware really is as bad as it comes, and when you’re faced with double or even triple extortion, you’ll be put in a tough spot that no business owner wants to find themselves in. Today, we want to cover what these terms are and why they’re so bad.
July 28, 2025
What Is Legacy Technology Costing Your Business?
It is certainly tempting to squeeze every last drop of life out of existing equipment. After all, why spend money on new computers or servers if the old ones still technically work? You may view this as frugal, but ironically not spending on the updated IT your business needs can lead to leaving significant revenue on the table. The truth is, holding onto outdated hardware can silently, yet significantly, bleed your business dry.

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