ARTICLE · 25 SEPTEMBER 2025

DOD Final Rule Incorporates CMMC 2.0 Into DFARS

Goodwin Procter LLP

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On September 9, 2025, the Department of Defense (DOD) issued the long-anticipated final rule to contractually implement the Cybersecurity Maturity Model Certification (CMMC) 2.0 program...

United StatesGovernment, Public Sector

Anne E. Railton

Bottom Line Up Front

On September 9, 2025, the Department of Defense (DOD) issued the long-anticipated final rule to contractually implement the Cybersecurity Maturity Model Certification (CMMC) 2.0 program, amending the Defense Federal Acquisition Regulation Supplement (DFARS). Beginning November 10, 2025, cybersecurity certification requirements will be incorporated into all DOD solicitations and contracts, except those for commercially available off-the-shelf items. The CMMC 2.0 program requirements will be implemented in phases over the next three years to minimize the impact of these sweeping changes. Contractors and companies seeking federal funding should prepare for the impact of these programmatic requirements on their business efforts.

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