On November 10, 2025, the Department of Defense’s new DFARS rule goes into effect, authorizing CMMC 2.0 requirements to appear in contracts for the first time. For small and mid-sized businesses (SMBs) in the defense industrial base, this is more than a policy milestone, it marks the beginning of a three-year rollout that will determine which companies remain eligible for defense work and which risk exclusion.
Decision-makers can no longer treat CMMC as a distant requirement. The countdown has begun, and organizations that prepare early will be positioned to win new contracts, maintain strong relationships with prime contractors, and avoid costly last-minute remediation.
What November 10 Means
Beginning November 10, contracting officers may insert CMMC requirements directly into solicitations and awards. While not all contracts will include them immediately, coverage will expand steadily until nearly all defense contracts involving Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) require compliance.
This phased rollout mirrors past federal cybersecurity mandates: organizations that act early gain a competitive advantage, while those that delay find themselves scrambling under deadlines and at higher cost.
Preparing Your Organization
Determine Your Required Level
CMMC 2.0 introduces a tiered model:
- Level 1 (Foundational): For companies handling only FCI; requires basic practices and annual self-assessment.
- Level 2 (Advanced): For companies handling CUI; aligns with all 110 NIST SP 800-171 controls. Some contracts will require a third-party certification, others will allow self-assessment.
- Level 3 (Expert): For the most sensitive programs; requires audits by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
Map Data Flows
Documenting where FCI and CUI reside, how they move, and who has access is essential. Without accurate data mapping, compliance efforts risk being incomplete and audit-readiness compromised.
Conduct a Pre-Assessment
A structured pre-assessment against NIST SP 800-171 and CMMC requirements will identify gaps in both technical and procedural controls. Many organizations discover the largest deficiencies are in documentation and policy, not just technology.
Build a Remediation Roadmap
Translate findings into a prioritized plan that covers technology upgrades, policy development, training, and monitoring. Decision-makers should allocate resources beyond IT tools, effective compliance depends equally on governance and workforce awareness.
Review Third-Party Dependencies
Managed Service Providers (MSPs), cloud services, and IT partners that touch your sensitive data must also meet compliance expectations. Incorporate vendor oversight into your CMMC strategy.
Elevate to the Executive Level
CMMC is not an IT-only issue. Treating compliance as a board-level priority ensures adequate resources, accountability, and integration into long-term business planning.
Why Early Action Matters
Organizations that begin preparation now will be positioned to demonstrate readiness to primes and contracting officers, gain a competitive edge in contract bids, and avoid rushed and expensive remediation under deadline pressure. Waiting until CMMC appears in your first solicitation means you are already behind.
How Netizen Can Help with CMMC Readiness
Meeting CMMC 2.0 requirements can be daunting, particularly for SMBs without dedicated compliance teams. Netizen provides CMMC pre-assessments that deliver a clear picture of your current posture, identify gaps, and provide a prioritized roadmap for remediation.
As an ISO 27001, ISO 20000-1, ISO 9001, and CMMI Level III certified Service-Disabled Veteran-Owned Small Business, Netizen has extensive experience guiding organizations in government, defense, and commercial sectors through complex regulatory requirements.
With the November 10 milestone fast approaching, now is the time to act. Start the conversation with Netizen today and move toward CMMC compliance with confidence.
