Phase 2
On hold
On July 13, 2026, the Department of War CIO suspended the November 2026 Phase 2 transition, the step that would have added Level 2 (C3PAO) requirements. No new date has been set.
Contracts
Being revised
DFARS Class Deviation 2026-O0025 (Revision 3, September 3, 2026) directs contracting officers to remove or revise CMMC requirements in new and existing solicitations and contracts. Contracts can still require CMMC Level 1 (Self) or Level 2 (Self). Existing contracts are changed at the next option period or administrative modification.
Your obligations
Still in force
If you handle CUI, DFARS 252.204-7012 still requires NIST SP 800-171 Rev. 2, and DoD can still run Medium or High assessments whose scores are posted in SPRS. If you handle FCI, the FAR basic safeguarding clause (now 52.240-93, formerly 52.204-21) still applies. If your contract includes a Level 1 (Self) or Level 2 (Self) requirement, you still post a current self-assessment in SPRS, and an affirming official still signs an affirmation every year.
What it means
The pause changes who checks your work, not the work itself. Contractors who use this window to close gaps will be ready whenever third-party assessments return, and they're on firmer ground for the affirmations they sign today.