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ARTICLE · 19 NOVEMBER 2025

DoD Begins Phased Implementation Of CMMC Final Rule: Key Actions For Contractors

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On November 10, 2025, the Department of Defense (DoD), also referred to as the Department of War (DoW), officially began rolling out its Cybersecurity Maturity Model Certification (CMMC) Final Rule...

United StatesGovernment, Public Sector
Angela B. Styles
Angela B. Styles
Michael J. Vernick
Michael J. Vernick
Evan D. Wolff
Evan D. Wolff
Edward Block
Edward Block
Rita S. Heimes
Rita S. Heimes
Maida Oringher Lerner
Maida Oringher Lerner
David Mahoney
David Mahoney
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On November 10, 2025, the Department of Defense (DoD), also referred to as the Department of War (DoW), officially began rolling out its Cybersecurity Maturity Model Certification (CMMC) Final Rule, marking the start of the program's phased implementation. CMMC requirements may now appear in new DoD solicitations, contract awards and option exercises.

Contractors should act now to:

  • Achieve and maintain the required CMMC level—eligibility for DoD contracts now depends on certification aligned with the sensitivity of information handled.
  • Identify whether your organization handles Controlled Unclassified Information (CUI) or Federal Contract Information (FCI) and where it resides—understanding CUI data flows is essential to determining the applicable CMMC level and scope of assessment for both CUI and FCI.

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