CMMC Reform Review Runs Past Its 60-Day Mark
The Department of War suspended CMMC Phase 2 on 13 July 2026 and gave a Reform Task Force 60 days to report. That window closed in mid-September; we found no published report as of 12 October, and no replacement date for the 10 November Phase 2 start.
Why It Matters
Phase 2 would have required third-party (C3PAO) Level 2 assessments for covered defense contracts from 10 November 2026. That expansion is paused, and the Department has said the review may change the assessment structure, the schedule, or both. With no report public and no new date, contractors are planning around an open question.
The suspension is not relief from the baseline. Phase 1 self-assessments, DFARS 252.204-7012, NIST SP 800-171, SPRS score posting and annual affirmations all remain in force, so enforcement risk sits with the self-attested record you already have on file.
Action Items
Pull your SPRS score — confirm it matches your current NIST SP 800-171 implementation, today.
Re-check your annual affirmation — make sure the evidence behind it is current and retrievable.
Keep Phase 2 readiness on a low simmer — don't cancel C3PAO scoping, but don't commit spend to a 10 November date.
On the Calendar This Week
13 Oct (1 day): NIST RFI on modernising the National Vulnerability Database (docket NIST-2026-0100) — comments close.
14 Oct (2 days): FedRAMP publishes its 20x Class D pilot requirements.
15 Oct (3 days): NIST SP 1353 (using AI for CSF analysis and reporting) — comments close.
→ More on the calendar: cybereyeq.github.io/podcast/calendar
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