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
December 4, 2024
Share Files More Effectively With These Practices
Businesses need tools to help their employees collaborate, and thankfully, there has never been a better time to find the ideal solution that works for your specific needs. Since so many individuals work remotely these days, developers have prioritized collaboration, and all businesses reap the benefits of this trend. One of the keys to effective collaboration is file sharing; nowadays, it’s never been easier to do it easily and efficiently.
December 2, 2024
3 Ways Data Breaches are Hard to Detect and Harder to Prevent
Unfortunately, cybersecurity is one of the most important topics to consider in today’s business world. A recent survey has shown that the majority of security leaders—approximately 67% of those surveyed—don’t know what caused a cybersecurity incident at their business. This is a shockingly high number that cannot be ignored, so let’s look at why data breaches are so challenging to identify and address.
November 29, 2024
Ever Wonder Where the Idea for Zero Trust Security Came From?
Zero-trust, an approach to cybersecurity gaining traction in the industry, is perhaps the most effective way to secure your business’ infrastructure. We want to take some time today to discuss how zero-trust came to be and how it compares to today’s cybersecurity threats.

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