CMMC Mandatory by DoD: What the November Timeline Means for Contractors
Nov 10, 2025
The Department of Defense has made it official: CMMC (Cybersecurity Maturity Model Certification) is mandatory for defense contractors. With the rollout tied to the 32 CFR Part 170 rule and phased contract requirements, the November timeline is a hard deadline for many in the defense industrial base (DIB). If you're still treating CMMC as optional, it's time to shift.
Why the DoD Made CMMC Mandatory
CMMC exists to protect Controlled Unclassified Information (CUI) and the supply chain. The DoD can no longer rely on self-attestation alone. Contractors must demonstrate a defined level of cybersecurity maturity (Level 1, Level 2, or Level 3) through assessments. Mandatory CMMC means no CMMC, no contract for covered work.
What "Mandatory" Actually Means for You
- New and renewed contracts will include CMMC requirements. If your contract involves CUI or other sensitive DoD information, you will need the appropriate CMMC level before award or at a specified phase-in date.
- Level 1 (Foundational) applies to contractors that handle Federal Contract Information (FCI). Assessment is self-attestation with annual affirmation.
- Level 2 (Advanced) applies when CUI is involved. This is where most defense contractors land. You need a third-party assessment from a C3PAO (Certified Third-Party Assessment Organization) or, during the transition, Joint Surveillance Voluntary Assessment Program (JSVAP) with the DoD.
- Level 3 (Expert) is for the most sensitive programs and the highest assurance.
November is a key date in the phased rollout. Missing the window doesn't just delay one contract; it can affect your ability to bid on future work and your standing in the DIB.
What to Do Before and After November 10
- Confirm your level. Map your contracts and data to determine whether you need Level 1, 2, or 3. Scoping drives everything.
- Close gaps. Use a CMMC gap assessment against NIST SP 800-171 (for Level 2) and the CMMC Assessment Guide. Fix the biggest risks first: identity, access, logging, and asset inventory.
- Lock in evidence. The DoD and C3PAOs want to see ongoing evidence, not a one-time snapshot. Build your System Security Plan (SSP), POA&Ms, and policies so they stay current and auditable.
- Plan for assessment. If you need Level 2, line up a C3PAO or understand the JSVAP path. Slots and timelines fill up; booking early reduces last-minute pressure.
Bottom Line
CMMC mandatory by DoD is not a rumor. It's the new rule. Use the November timeline as the trigger to get your program in shape, align with 32 CFR Part 170, and keep your place in the defense supply chain.