What the November 10 CMMC Deadline Means for Defense Contractors
- Max Heinemann
- Nov 10
- 2 min read
The Department of Defense’s CMMC enforcement begins November 10, 2025. Learn what this milestone means, how it affects contractors, and how Cyberleaf’s four-phase approach helps you achieve compliance efficiently and at scale.
The CMMC Rule Becomes Real
On November 10, 2025, the Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) program moves from policy to practice. Beginning this date, contracting officers can start including CMMC requirements in new solicitations and awards. For organizations that handle Controlled Unclassified Information (CUI) or Federal Contract Information (FCI), this is no longer preparation—it is performance.
The final rule, published in September, formally amends the Defense Federal Acquisition Regulation Supplement (DFARS) to make CMMC compliance a contractual requirement. In short, cybersecurity maturity is now a condition for doing business with the DoD.
Why November 10 Matters
This date marks the start of Phase 1 in the Department of Defense’s phased rollout of CMMC over the next three years.
Beginning November 10:
- CMMC clauses may appear in new contracts and solicitations.
- Contractors must perform at least a self-assessment for CMMC Level 1 or Level 2.
- Some contracts may immediately require a third-party assessment.
- Prime contractors must ensure their subcontractors meet compliance requirements as part of their flow-down obligations.
- Existing DoD suppliers may need to update their System Security Plan (SSP) and POA&M before contract renewal.
For many organizations, this means that eligibility to bid or renew DoD contracts now depends on documented cybersecurity practices.
What Contractors Need to Do
Determine Scope: Identify which systems process, store, or transmit CUI or FCI. Only those systems fall within the CMMC boundary.
Assess Your Readiness: Conduct a gap analysis to determine current maturity against NIST SP 800-171 controls and CMMC Level 1 or 2 standards.
Develop a Plan of Action: Create a roadmap that prioritizes remediation and control implementation within defined timelines.
Implement and Document: Apply the required controls, policies, and procedures—and capture documentation for assessment or audit.
Sustain Compliance: Maintain continuous monitoring, regular evidence collection, and periodic reassessment to ensure compliance over time.
Cyberleaf’s Four-Phase Path to Compliance
Cyberleaf simplifies the CMMC journey with a structured approach designed for efficiency and scalability:
1. Assess: Identify current gaps and define your baseline
2. Plan: Build a detailed roadmap and compliance strategy
3. Implement: Execute required security controls and documentation
4. Maintain: Provide continuous monitoring and compliance support
Whether you are preparing for a self-assessment or a certified third-party audit, our team delivers the expertise and orchestration needed to get you there.
Looking Ahead
The November 10 milestone signals the start of CMMC enforcement, not the end of preparation. Over the next three years, the DoD will expand CMMC requirements across more contracts until full implementation in 2028.
Organizations that act now will not only stay eligible for future contracts but will also strengthen their security posture and trust within the defense supply chain.
Let’s Talk
If your organization supports the Department of Defense, the time to act is now. Talk with Cyberleaf’s CMMC consultants to start your path to compliance and stay ready for what comes next.