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 14, 2025
Three Reasons Downtime is Really Bad for Your Business
Experiencing downtime can severely harm your business. If you're not actively monitoring your network to minimize it, you're putting your operations at risk. Downtime refers to any period when your organization isn't functioning as intended, and it's crucial to manage it diligently. Failing to do so can lead to several challenging issues.
February 12, 2025
Tip of the Week: Sick of Google’s AI Overviews? Here’s How to Say Goodbye
Artificial intelligence—AI—is rapidly appearing in more and more contexts, but one most people have almost certainly seen by now is at the top of Google’s search engine results. For those who would rather not see these generated results—which have been found to be occasionally contradictory or outright wrong, depending on the source the AI has drawn from—there are actually a few ways to accomplish this.
February 10, 2025
The Fascinating History of the Cut, Copy, and Paste Shortcuts
Technology can do some incredible things, but there’s a reason why basic tools still remain popular even to this day. It’s because they cracked the code for productivity, and they are so easy that anyone can use them. For example, there’s the Cut, Copy, and Paste commands that can be used in literally any application out there.

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