The clock is ticking. On November 10, 2025, the Cybersecurity Maturity Model Certification (CMMC) 48 CFR Final Rule takes effect. This milestone is not just another policy update, it marks the beginning of mandatory enforcement for all new Department of Defense (DoD) contracts.
There is no grace period. If your organization is not certified at the required CMMC level by the time you bid on a contract, you will be disqualified.
What Changes on November 10?
- Contract Language Shifts – DoD contracting officers will begin inserting CMMC requirements into all new solicitations.
- Mandatory Assessments – Depending on contract scope:
- Level 1 Self-Assessment – For organizations handling only Federal Contract Information (FCI).
- Level 2 Self-Assessment – For some contracts with low-sensitivity CUI/SPD.
- Level 2 Certification (via C3PAO) – Required for contracts involving sensitive Controlled Unclassified Information (CUI).
- Supply Chain Expansion – Subcontractors, service providers, and other downstream vendors may be required to meet CMMC requirements due to flow-down clauses.
Why the Urgency?
- No Grace Period – Enforcement begins immediately on November 10.
- Long Preparation Timeline – Achieving Level 2 certification can take 12-24 months, from gap analysis to remediation and assessment.
- Competitive Risk – Organizations that delay will lose contract eligibility to competitors who are audit-ready.
Steps You Should Take Right Now
- Determine Your Required Level – Confirm whether you handle FCI, CUI, or more sensitive information.
- Scope Your Environment – Identify systems, people, and processes that fall under CMMC.
- Conduct a Gap Analysis – Measure your current practices against NIST 800-171 requirements.
- Remediate Quickly – Implement missing controls, document policies, and close vulnerabilities.
- Engage a C3PAO – If Level 2 certification is required, schedule an authorized assessment before demand exceeds capacity.
The Bottom Line
November 10, 2025, is not a soft deadline, it’s a hard stop. Contractors that aren’t prepared will be locked out of DoD opportunities. The Defense Industrial Base is moving into a new era of accountability, and only organizations that act now will remain competitive.
How Gavii Can Help
At Gavii, we specialize in guiding defense contractors through every stage of CMMC compliance, from readiness assessments and gap analysis to documentation and training.
Don’t wait until November. Contact us today to secure your place in the DoD supply chain.
