By: Jan Fourman, PhD, EdD, MBA
Do you currently have a DoD contract? Do you want one soon? If you say “yes” to either question, you need to know important cyber legal requirements if you handle Controlled Unclassified Information (CUI).
The important update is that CMMC Revision 3, along with its companion assessment publication NIST SP 800-172A Revision 3, is now live. This is a phased rollout that has already started. On November 2026, most contractors handling CUI will not be able to self-certify your cyber readiness. After that date, you’ll need to use a third-party auditor.
But let’s go back in time a bit to address any revision questions. CMMC Revision 2 was published in February 2021. This update added 39 requirements focused on confidentiality. So, why update again? Revision 3 expands the coverage to, not only confidentiality, but integrity and availability.
Now here’s the confusing part. Revision 2 will still be used alongside Revision 3. The Revision 2 is your baseline, so nothing changes operationally. In CMMC, Revision 3, Level 2 is the core enforceable baseline. What changes is the assessment choices stated previously – from self-assessment to having a formal third-party audit.
We shouldn’t be surprised. The DoD has been preparing us for this revision since their publication of a memorandum defining exact Organization-Defining Parameters (ODPs) for updated NIST SP 800-171,Revision 3. The memo, released on April 15, 2025, set specific values that defense contractors must use for their cybersecurity controls. Key areas outlined standardized values for criteria of invalid logon attempts, threat/vulnerability reporting, cryptographic key management and system auditing.
Key Steps for Contractors
First, understand your requirements. Over 90% of us are required to fully comply with the 110 controls outlined in NIST SP 800-171 Revision 2. Second, understand that the changes in assessment will be a phased rollout. Phase 1 is now through November 10, 2026. Self-assessment is allowed now through November 10 for Level 2 CUI contracts. Phase 2 starts after November 10, 2026, when no more self-assessments will be allowed. However, between now and November 10, the DoD can still require a full third-party audit. Plus, you are still required to fill out an annual affirmation regardless of self-assessment or formal third-party audit. This annual assessment is the DoD’s Supplier Performance Risk System (SPRS).
Wait! Do I really need CMMC Level 2?
Yes. CMMC Level 2 is now your cybersecurity readiness requirement. But what if I already have a Plan of Action and Milestones (POA&M)? For those of you that don’t know about POA&Ms – In cybersecurity, this is a document that identifies tasks needed to address security vulnerabilities. POA&Ms outline the control gaps caused by the weaknesses with corrective actions to be taken. In addition, you are required to follow strict POA&M rules. For example, you’re permitted to take fewer than 10 risk-based gaps that need to be filled within a specific timeframe.
While the POA&M is an important tool in the CMMC framework, it won’t let you put off the assessment deadline this coming November. Misunderstanding these rules can put eligibility for current or future DoD contracts at a risk. POA&Ms must be completed before any assessments can be initiated.
What are my next steps?
Continue pursuing or maintaining Level 2 certification against NIST SP 800-171 Revision 2. It is still current and your enforceable baseline. However, familiarize yourself with CMMC Revision 3, as this is where requirements are heading.
We welcome your questions and comments. We’ll keep you updated. Contact us at industryworkforcesolutions.com.
References
CMMC. (2026). CMMC POA&Ms and critical requirements: What you can and can’t defer as the enforcement deadline approaches. Retrieved from cmmc.com/
CMSCyberGeek. (2026). Plan of Action & Milestones (POA&M). Retrieved from security.cms.gov/
Cyberxgov Solutions. (2026). CMMC Rev. 3 compliance in 2026: What defense contractors must know before it’s too late. Retrieved from cyberxgovsolutions.com/
DoD. (2025). Memorandum for senior Pentagon leadership Commanders of the Combatant Commands, Defense Agency and DoD Field Activity Directors. Retrieved from dodcio.defense.gov/
Ecuron. (2026). NIST SP 800-172 Rev.3 is final: DOD can now update both CMMC levels at once. Retrieved from CMMC@ecuron.com/
