Compliance Is Now a Contract Gate
The wait is over. On August 25, 2025, the Office of Information and Regulatory Affairs (OIRA) officially cleared the Department of Defense’s acquisition rule on the Cybersecurity Maturity Model Certification (CMMC). This rule will soon be published in the Federal Register and become effective, marking the beginning of real contract enforcement. If you’re a defense contractor, this is your call to action.
Only about 270 contractors are fully certified today, yet up to 80,000 are expected to require Level 2 certification. That leaves a massive compliance gap and a major opportunity for those who act now.
The Alphabet Soup You Can’t Ignore
Understanding the acronyms helps decode the urgency:
- OIRA (Office of Information and Regulatory Affairs): Cleared the final policy gate.
- DFARS (Defense Federal Acquisition Regulation Supplement): Houses the contract clauses that will now enforce CMMC.
- SPRS (Supplier Performance Risk System): Where contracting officers will check your compliance status.
Once the rule goes live, missing or outdated entries in SPRS can disqualify you from awards, even if your technical proposal is perfect.
What Changed and Why It Matters
The CMMC program rule (Title 32) set the policy. The acquisition rule (Title 48) puts teeth in it. Soon, contract solicitations will specify the required CMMC level, and your SPRS status will be a gate to bidding or contract renewal.
Phased Rollout: What to Expect
Starting 1–60 days after publication, the Department of Defense will begin implementing CMMC in phases:
- Phase 1: Level 1 or 2 self-assessments required for new awards.
- Phase 2: Level 2 third-party assessments begin.
- Phase 3+: Level 3 assessments introduced for the highest-risk contracts.
Don’t get caught flat-footed. Once it starts, noncompliance means disqualification.
What You Must Do Now
Here’s your game plan:
- Identify Your Required Level
If you handle Federal Contract Information (FCI), Level 1 applies. Controlled Unclassified Information (CUI)? You’re in Level 2 territory. - Scope Your Environment
Understand which systems, people, and vendors process FCI or CUI. This defines your assessment scope and prevents surprises. - Complete Your Self-Assessment
Level 1 requires 15 basic controls (FAR 52.204-21). Level 2 demands compliance with NIST SP 800-171 rev2 and posting in SPRS. - Post to SPRS and Affirm
Your compliance doesn’t count unless it’s visible. Post your scores and execute senior affirmation in SPRS. - Engage Experts for Help
Partner with a Cyber-AB Registered Practitioner Organization like Alluvionic. We manage the heavy lifting, policies, procedures, evidence collection, gap remediation, and audit prep, so you can focus on your mission.
Why Partner with Alluvionic?
We don’t just tell you what’s wrong. We fix it with:
- Proven project management that respects your time and budget
- End-to-end CMMC readiness
- vCISO support for leadership and oversight
- Relationships with C3PAOs to streamline third-party assessments
See how our CMMC Services simplify compliance and reduce risk.
Last Call Before the Gate Closes
CMMC is no longer “coming soon”…it’s happening now. Contractors who delay risk falling behind, losing awards, or being forced to scramble under pressure. Those who prepare will win contracts, build trust, and help secure the defense supply chain.
Get a trusted partner. Get compliant. Get ready.
Contact Alluvionic Today to schedule your CMMC readiness consultation.