CMMC Final Rule Submission Signals Urgency: Time is Running Out for Compliance

CMMC Final Rule Submission Signals Urgency: Time is Running Out for Compliance

As a Registered Practitioner Organization (RPO) dedicated to CMMC compliance, Tego is committed to keeping our clients informed on the latest developments.  We have consistently urged Organizations Seeking Certification (OSCs) not to procrastinate on their compliance journey, and now, more than ever, that advice is critical.

On July 22, 2025, the Department of Defense (DoD) submitted the final rule for incorporating CMMC requirements into federal contracts under Title 48 to the Office of Information and Regulatory Affairs (OIRA) for review.  This milestone marks a significant step forward, bringing us closer to mandatory implementation.

What does this mean for organizations pursuing CMMC compliance?

  1. Phased Roll-Out is Imminent.
    Once the rule is published, the phased integration of CMMC into DoD contracts is anticipated to begin between late October 2025 and early February 2026, with a strong likelihood of starting in mid-2025.
  2. Steer Clear of Outdated or Misleading Information.
    • Be cautious of any claims that offer specific deadlines or timelines based on outdated guidelines. Verify sources to avoid confusion from ambiguous or inaccurate details. 
    • Waivers will be extremely limited, specific to entire classes of acquisitions, and often temporary workarounds that will not apply once a solicitation is issued.  
    • Avoid relying on self-assessments for Level 2 compliance in Phase 1.  The DoD has the discretion to require third-party C3PAO certifications from the outset for contracts that handle sensitive data, such as Controlled Unclassified Information (CUI) and Controlled Technical Information (CTI). 
    • Misconceptions abound, such as the notion that Level 2 C3PAO certification can’t be mandated early.  You must know that guidance explicitly allows that, and hoping that isn’t true could leave you unprepared when solicitations demand full certification before award.

Why does this matter now?

  1. Contract Requirements Are Approaching Quickly: New DoD contracts will soon require CMMC certification upon publication of the final rule, putting non-compliant organizations at risk of losing opportunities.
  2. The Window for Preparation is Narrowing: With implementation likely starting in Q4 2025, procrastinators face a shrinking timeline to assess, remediate, and certify.  Delays could lead to failed, rushed attempts or missed deadlines.
  3. Act on Reliable Guidance: Rely on trusted compliance experts to navigate this evolving landscape, avoiding hype or unsubstantiated promises that could derail your progress.

This submission to OIRA is a clear signal that the era of waiting is over.  We anticipate a surge in demand for pre-assessments and compliance support as 2025 draws to a close.  If you have been putting off your CMMC preparations, DO NOT delay any longer!  Contact Tego today to get started and secure your path to compliance before the deadline passes.

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About the author
Jennifer Vosburgh
Jennifer Vosburgh is a seasoned Marketing and Communications professional. With over 15 years of experience, she has a strong background in Marketing, Communications, and Event Management. As Vice President of Tego Data Systems in Raleigh, NC, Jennifer is responsible for delivering full-scale Marketing Campaigns across all platforms including website, email, social media, events, and more.

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