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ARTICLE · 15 JULY 2026

Reassessing CMMC: DOD Suspends CMMC Phase II, But Core DFARS Obligations Endure

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The U.S. Department of Defense has temporarily suspended CMMC Phase II requirements pending a comprehensive review by a newly established Reform Task Force. What does this suspension mean for defense contractors' cybersecurity obligations, and how will the reformed framework balance security needs with accessibility for businesses of all sizes?

United StatesGovernment, Public Sector
Thomas Pettit
Thomas Pettit
Ronald Lee
Ronald Lee
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On July 13, 2026, the U.S. Department of Defenser (DOD) temporarily suspended Cybersecurity Maturity Model Certification (CMMC) Phase II requirements — originally scheduled to take effect on November 10, 2026 — pending a review by the CMMC Reform Task Force. (Our September 2025 Advisory detailed the CMMC phases and other CMMC program requirements.) DOD suspended CMMC Phase II due to concerns about “prohibitive compliance costs, severe shortages in third-party assessment capacity, and complex regulatory timelines” as well as reports from the Small Business Administration indicating “that the current CMMC program is structurally incompatible with our need to rapidly expand the DIB [Defense Industrial Base].”

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