CMMC 2.0 Deadline Is Here: What Defense Contractors Still Get Wrong

Defense Signals™ | Compliance & Risk Signals

THE SIGNAL

CMMC 2.0 enforcement is no longer a future event. Contracts with CMMC requirements are being awarded now. Small defense contractors who treated this as a planning exercise are discovering it is an execution requirement — and some are discovering it too late.

WHAT THE SIGNALS SHOW

Three persistent misreads are costing contractors their competitive position:

1. Self-Assessment Is Not the Same as Compliance CMMC Level 2 requires a third-party assessment by a C3PAO for most contracts. Many small businesses submitted self-assessments to SPRS assuming that satisfies the requirement. It does not — not for contracts requiring Level 2 certification.

2. POA&Ms Are Not a Safe Harbor A Plan of Action and Milestones indicates you know you have gaps. Contracting officers are increasingly treating open POA&Ms as a risk signal, not a compliance pathway. If your POA&Ms are not closing, your competitive position is eroding.

3. Subcontractors Are Not Exempt Flow-down requirements mean your CMMC obligation extends to any subcontractor handling Controlled Unclassified Information. If your sub isn't certified and your contract requires it, the liability flows up.

WHAT THIS MEANS FOR YOU

If you have active DoD contracts or active pursuits with CUI requirements, your CMMC status is a competitive variable — not just a compliance checkbox. Primes are beginning to screen teaming partners on certification status before RFP release.

Get assessed. Close your POA&Ms. Verify your subs.

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Defense Signals™ | Compliance & Risk Signals