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ARTICLE · 15 JULY 2026

DoW Pauses CMMC Third-Party Assessment Regime—Could This Be CMMC 3.0?

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On July 13, 2026, the Department of War (DoW) announced the immediate suspension of the Cybersecurity Maturity Model Certification (CMMC) Phase II requirements that were originally scheduled to take effect on November 10, 2026.

United StatesTechnology
Angela B. Styles
Angela B. Styles
Marta A. Thompson
Marta A. Thompson
Colin M. Huntley
Colin M. Huntley
Sara McLean
Sara McLean
Evan D. Wolff
Evan D. Wolff
Laura Hill
Laura Hill
Maida Oringher Lerner
Maida Oringher Lerner
Edward Block
Edward Block
David Mahoney
David Mahoney
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On July 13, 2026, the Department of War (DoW) announced the immediate suspension of the Cybersecurity Maturity Model Certification (CMMC) Phase II requirements that were originally scheduled to take effect on November 10, 2026. Phase II is the stage of the CMMC rollout that would have made third-party assessments by certified CMMC Third-Party Assessment Organizations (C3PAOs) a condition of many contract awards. This announcement will be a relief to many in the defense industrial base.

Importantly, DoW made clear that all Phase I self-assessment requirements remain firmly in place, and that the action “does not eliminate the requirement for companies to protect federal data.” Contractors must continue to comply with applicable requirements for safeguarding Federal Contract Information and Covered Defense Information, including Federal Acquisition Regulation (FAR) 52.204-21 and Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012. For contractors, the practical

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