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
May 9, 2025
Adjusting Your Business IT Approach Can Bring Greater Outcomes
Is your business technology a tangled web of frustrations? You're certainly not navigating this digital dilemma alone. We frequently hear from organizations grappling with sluggish networks, outdated software that feels like a relic from the dial-up era, and the ever-present anxiety of safeguarding crucial business data.
May 7, 2025
A Quick Introduction to the Drives in Microsoft Windows
Windows is, for the most part, the default operating system you can expect to see in a business setting. That said, some owners have never used a Windows computer before, instead using a simple Chromebook or a Mac. Still, it’s good to know how Windows works, especially since it seems there’s a significant gap in knowledge.
May 5, 2025
How Your Business Can Implement Better Cybersecurity Training Practices
Cybersecurity isn’t the most fun thing to talk about, but it’s still important. This is especially for your employees who are on the front lines, the most likely folks to encounter threats during their day-to-day tasks. Today, we want to cover how your business can build better cybersecurity training practices that can keep your business secure for the long haul.

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