Question · CMMC

Is CMMC required now, or is it still being phased in?

CMMC verifies that defense contractors meet existing safeguarding requirements for FCI (FAR 52.204-21) and CUI (NIST SP 800-171), with three levels and either self-assessment or third-party or government assessment.

AboutCMMC
Legal forceBinding on DoD contractors through contract
Applies from10 Nov 2025
Checked21 Oct 2026

01 / The answer

The short answer

CMMC is required now, but only at Phase 1 levels. Since the DFARS rule took effect on November 10, 2025, DoD solicitations can require Level 1 (Self) or Level 2 (Self) status, posted in SPRS with an annual affirmation. Phase 2, which would have added third-party (C3PAO) Level 2 certification from November 10, 2026, was suspended by the Department of War on July 13, 2026 pending a CMMC Reform Task Force review. DFARS 252.204-7012 and NIST SP 800-171 Rev. 2 still apply in full.
CMMC · checked 21 Oct 2026

02 / The rule

What CMMC requires

CMMC verifies that defense contractors meet existing safeguarding requirements for FCI (FAR 52.204-21) and CUI (NIST SP 800-171), with three levels and either self-assessment or third-party or government assessment. Phase 1 (self-assessments as a condition of award) took effect November 10, 2025; on July 13, 2026 the Department of War suspended Phase 2, which would have required C3PAO certification from November 10, 2026, pending a CMMC Reform Task Force review.

  1. 01Level 1: annually self-assess against the 15 FAR 52.204-21 safeguarding requirements and affirm in SPRS.
  2. 02Level 2: meet the 110 NIST SP 800-171 Rev. 2 requirements, by self-assessment or C3PAO assessment every three years.
  3. 03Level 3: hold Level 2 certification plus a government (DIBCAC) assessment of 24 NIST SP 800-172 requirements.
  4. 04Post results in SPRS and have a senior official affirm compliance annually.

03 / Records

Records to keep

  1. 01System security plan covering the assessment boundary
  2. 02SPRS score and annual affirmation records
  3. 03Plan of action and milestones with closeout dates
  4. 04CMMC certificate or self-assessment results and UID

Optional evidence · where Planisphere fits

Keep a record anyone can check

When your team meets a duty, Planisphere can seal the event it reports as a receipt.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

Paste the receipt into Verify. No account or key.

A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.

SOURCES

Go back to the source

SECONDARY

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