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ARTICLE · 18 SEPTEMBER 2025

CMMC Final Rule: Key Takeaways For Defense Contractors

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On September 10, 2025, the Department of Defense (DoD) completed the Cybersecurity Maturity Model Certification (CMMC) rulemaking process. CMMC comprises two regulatory regimes.

United StatesGovernment, Public Sector
Thomas Pettit
Thomas Pettit
Ronald Lee
Ronald Lee
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On September 10, 2025, the Department of Defense (DoD) completed the Cybersecurity Maturity Model Certification (CMMC) rulemaking process. CMMC comprises two regulatory regimes. 32 C.F.R. Part 170 establishes the CMMC program requirements (the Program Rule), and the September 10, 2025 final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) (the DFARS Rule) establishes DFARS policies, contract clauses, and other provisions to implement the Program Rule. This Advisory discusses key takeaways for DoD prime contractors and subcontractors.

CMMC Overview

  • Effective Date/Phase 1 Start Date: In accordance with 41 U.S.C. § 1707, the DFARS Rule takes effect on November 10, 2025 (60 days after publication). Phase 1 of the four-phase process for implementing CMMC begins that same day.1

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