Written By Paige Langmead, CCP CCA
As of July 2025, the Department of Defense has reached a significant milestone in the rollout of the Cybersecurity Maturity Model Certification (CMMC) program. The final rule regarding CMMC, codified under Title 48 of the Code of Federal Regulations (CFR), has officially been submitted to the Office of Management and Budget (OMB) for review. This submission marks one of the last formal steps before the rule becomes enforceable across the Defense Industrial Base (DIB).
What Does This Mean for Defense Contractors?
The OMB’s review process typically spans between 30 to 60 days. Following this period, the rule enters a 60-day effective period before full enforcement begins. Based on this timeline, it is anticipated that CMMC requirements will start to appear in Department of Defense contracts as early as mid-October 2025, potentially by the Thanksgiving holiday.
For defense contractors, this development signals that preparations must accelerate. The introduction of these regulations aims to enhance the protection of Controlled Unclassified Information (CUI) and strengthen the cybersecurity resilience of organizations that operate within the defense supply chain.
Key Actions for Contractors
To ensure readiness for compliance under the new rule, contractors should take immediate steps to:
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- Review and validate existing cybersecurity protocols.
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- Confirm alignment with NIST Special Publication 800-171 requirements.
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- Establish engagement with an accredited CMMC Third-Party Assessment Organization (C3PAO) or trusted cybersecurity partner.
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- Prepare for upcoming CMMC assessments under the finalized regulatory framework.
This proactive approach will help mitigate risks of non-compliance and secure contracts in an evolving regulatory environment.
Looking Ahead
As the regulatory process continues, stakeholders should expect further guidance and resources to support compliance efforts. We remain committed to providing timely updates and expert insights as the CMMC program advances toward full implementation. Contact KTL today to learn more about how we can help!