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Understanding the CMMC Pause: Key Changes and Action Steps

On July 13, 2026, the Department of War announced the immediate suspension of CMMC Phase II requirements. The move was memorialized in a memo dated July 10, 2026, signed by DoW Chief Information Officer Kirsten Davies. Those requirements had been scheduled to take effect on November 10, 2026, and would have pushed many contracts handling Controlled Unclassified Information (CUI) into mandatory third-party C3PAO assessments.

The stated goal is straightforward: reduce compliance barriers for small, medium, and non-traditional businesses so the Defense Industrial Base can expand faster under the Department’s current acquisition priorities.
A 60-day CMMC Reform Task Force review is now underway, including a public Request for Information seeking industry input on cost drivers and administrative burden. Phase I self-assessment requirements remain firmly in place.

This is not a free pass.
It’s a pause on one layer of bureaucracy — not a suspension of the underlying security obligations.

What Actually Changed (and What Didn’t)

Suspended

  • The November 2026 transition to Phase II — third-party Level 2 assessments as a condition of award in many cases.
  • Pending and future CMMC implementation milestones (including Phase III and IV) that would have required C3PAO or DIBCAC assessments.
  • During the review period, contracting officers are limited to requiring only Level 1 (Self) or Level 2 (Self) assessments in new procurements.
  • Existing contracts that already contain Phase II language will have that language removed by modification, either before the next option period or at the next scheduled administrative update.

Still fully in force

  • Phase I self-assessments and annual affirmations in SPRS.
  • DFARS 252.204-7012 obligations to protect covered defense information and implement NIST SP 800-171 controls.
  • Contractual cybersecurity requirements that primes flow down to subcontractors.
  • The Department of Justice’s Civil Cyber-Fraud Initiative, which continues to treat inaccurate self-assessments and false claims seriously.

The official release is worth reading in full: Forging the Arsenal of Freedom: Department of War Suspends CMMC Phase II Requirements. The SBA has also publicly backed the move, arguing the prior framework was pushing small firms out of the defense supply chain.

In short: the certification theater got paused. The requirement to actually protect the data did not.

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