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The Department of Defense’s (DOD) has at long last submitted its’ final rule to the Office of Information and Regulatory Affairs (OIRA) for final review, “Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041).” 

The submission is a game changer for the defense sector, as it marks a critical milestone for the Cybersecurity Maturity Model Certification (CMMC) program, indicating an estimated Q4 start to the rollout and enforceability. 

While the CMMC program has been it’s its final form since December 2024, the DoD cannot enforce it until the accompanying Title 48 DFARS regulation is cleared by OIRA and signed off by the DoD – a process that can take anywhere from 90 to 120 days. 

Let’s break down what this means to the defense industrial base and what you can do to effectively prepare: 

1.  CMMC Will Soon be Enforceable  

After years of skepticism since Title 48’s release in 2020, the regulation is rapidly moving forward. Requirements are expected in contracts as early as October, making certification mandatory—not optional—for contractors seeking DoD work. 

2. Contract Eligibility Just Got Tighter

Most contractors bidding on DoD contracts will be required to self-attest or certify at CMMC Level 1 or Level 2, depending on whether they handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI).  

3. Clear Compliance Timelines are Coming 

Once the final rule is published, it will establish a definitive rollout timeline for CMMC and provide concrete requirements for contractors. Every DoD contract will specify the required CMMC level, ending the uncertainty that has surrounded the program for years. 

4. DoD signals Urgency

The expedited OMB review highlights the DoD’s urgency and national security priority to secure sensitive controlled unclassified information across its supply chain. As cyber threats and advanced persistent threats grow at an exponential rate and become more sophisticated, the message is clear: contractors must adapt to meet these challenges.    

Let’s talk details: 

For those of you who are knee deep in regulatory compliance, be aware this amendment acts as the “companion” rule to the 32 CFR (final CMMC rule) and once cleared will direct contracting offices on when and where to insert the DFARS 7021 clause, providing the framework and contractual requirements of the CMMC program into contracts. Once OIRA clears the rule, the DFARS 252.204-7021 clause will move forward for publication in the federal register, triggering the first phase of the long anticipated CMMC Program rollout.   

In phase 1 of the rollout, per the 32 CFR, the DoD intends to include the requirement for CMMC Statuses of Level 1 (Self) or Level 2 (Self) for all applicable DoD solicitations and contracts as a condition of contract award. DoD may, at its discretion, include the requirement for CMMC Status of Level 1 (Self) or Level 2 (Self) for applicable DoD solicitations and contracts as a condition to exercise an option period on a contract awarded prior to the effective date. DoD may also, at its discretion, include the requirement for CMMC Status of Level 2 (C3PAO) in place of the Level 2 (Self) CMMC Status for applicable DoD solicitations and contracts. 

With cyber threats growing more refined and intricate, contractors must evolve or be left behind. 

Industry Implications: 

• The fast-moving DFARS rule is a wake-up call: CMMC readiness can’t wait. 

• Proactive compliance today = contract eligibility tomorrow. 

• Early movers will secure their spot in the defense ecosystem and position themselves for long-term success. 

Choose your Partners Wisely   

For small and mid-sized businesses (SMBs), selecting the right Managed Service Provider (MSP) is a critical step to achieving and maintaining CMMC compliance, in a reasonable timeframe.  

Be sure you ask good questions: 

• Are they CMMC Level 2 certified? Have they, and their customers passed an audit?  

• How do they handle incident response for their organization and if they are onboarded to your organization? 

• Are they experienced in DFARS 7012, NIST 800-171, and GCC High environments? 

• Do they provide a SIEM and/or Security Operations Center or SOC service?  

• Can they share a Customer Responsibility Matrix that outlines clear roles and responsibilities, delineating what your organization “owns” vs. what your MSP covers?  

• Will someone from their team be present during your assessment? 

Working with a Certified MSP 

For contractors without sufficient in-house resources, working with a certified MSP can help reduce risk, save time, and ensure readiness as CMMC enforcement begins. 

NeoSystems, a CMMC Level 2 certified Managed Service Provider (MSP), supports Defense Industrial Base (DIB) contractors with meeting CMMC and NIST 800-171 requirements. Their managed information system is designed for organizations handling Controlled Unclassified Information (CUI), offering a compliant infrastructure and ongoing support. 

NeoSystems provide powerful and easy to consume technology solutions with program and, critically, support through the entire assessment process. Our comprehensive services include onboarding into Microsoft GCC/GCC High environments, ongoing risk and control assessments, continuous compliance monitoring, and full third-party assessment support. NeoSystems has helped a range of organizations prepare for and pass C3PAO assessments, maintain compliance, and manage the operational demands of cybersecurity and ongoing compliance requirements. 

Key Takeaways for Government Contractors: 

The OMB’s review of the DFARS final rule is a defining moment for defense contractors. With Phase 1 of CMMC rollout imminent, complacency is not an option.  

Now is the time to: 

• Assess your cybersecurity posture and address compliance gaps immediately. 

• Self-certify or prep for a C3PAO audit — before proposals are due. 

• Early action = eligibility. Delay = lost contracts. 

• Build trusted partnerships with trusted, experienced and certified providers 

The organizations that are taking action now will be the ones ready to win tomorrow’s contracts.  

Get Started Today 

Explore NeoSystems’ CMMC services and discover how they can help your business achieve compliance. Visit NeoSystems CMMC Compliance Services to take the first step.