Executive Brief
Waiting to start your Cybersecurity Maturity Model Certification (CMMC) prep might feel strategic, but it’s not. The longer defense contractors wait, the higher the operational, financial, and reputational cost of catching up later. With CMMC now entering full enforcement, readiness is quickly becoming a differentiator across the Defense Industrial Base (DIB).
- Delaying readiness can trigger rescoping costs, stalled projects, rushed remediation, audit delays, and lost contract opportunities.
- Prime contractors are already using supplier scorecards to gauge CMMC progress.
Want to learn more about what’s behind the certification logjam? Dig deeper below.
Why Delays Are Riskier Than They Look
CMMC is no longer a distant policy goal; it’s now a contract reality. The 48 CFR rule was published on September 10, 2025, and becomes effective November 10, 2025, officially adding certification as a condition for new awards. Its companion rule, 32 CFR Part 170, is already in effect and lays the foundation for compliance requirements.
Delaying certification prep means competing for limited assessment capacity once enforcement begins, and those who wait risk missing entire bid cycles.
- Certified Third-Party Assessment Organizations (C3PAOs) bottleneck: C3PAOs are limited, and demand will spike after November 2025.
- Timeline compression: The closer to enforcement in November, the harder it becomes to find open C3PAO assessment slots or enough time to fix findings.
- Lost readiness time: Achieving CMMC Level 2 can take 12 to 18 months depending on your baseline maturity.
In short, waiting for the rule to fully take effect is the fastest way to fall behind.
The Real Cost: Staffing, Rescoping, and Rework
Contractors often underestimate how much internal friction delayed CMMC prep creates. The issue isn’t just compliance, it’s resourcing, project management, and long-term sustainment.
- Staffing shortfalls: Teams without CMMC assessment experience risk failing their initial review, forcing them to restart the process and incur duplicate costs for re-assessment.
- Rescoping: Many late-starting contractors realize too late their environments are too large, forcing rushed segmentation or redesigns to meet Level 2 requirements.
- Rework: Incomplete or generic documentation (i.e. System Security Plans) often fail third-party review, leading to costly and longer audit cycles.
Every delay compounds both cost and complexity.
How Primes Are Currently Enforcing Readiness
While formal enforcement begins in November, prime contractors aren’t waiting. Many have already implemented internal supplier assessments to reduce their own risk exposure.
- Supplier scorecards: Primes are ranking subcontractors based on Supplier Performance Risk System (SPRS) scores, documentation maturity, and audit readiness.
- Existing flow-downs: Under DFARS 252.204-7012, subcontractors have long been required to implement National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 controls. What’s changing under CMMC is that those same requirements now need to be independently validated.
- Transparency pressure: Early-ready contractors stand out when primes report their supply chain’s cybersecurity posture to the DoD.
ISI Insight: readiness isn’t just regulatory; it’s becoming part of every competitive evaluation.
Readiness Is a Competitive Advantage
Early adopters are already reaping the benefits of getting ahead. They’re securing stronger positions in bids, avoiding audit scheduling delays, and reinforcing their reputations as trusted suppliers.
- Positioned for less competition
- Stronger positioning for new bids
- Reduced last-minute remediation risk
- Enhanced trust with primes and government customers
CMMC certification isn’t a box to check; it’s a mark of operational maturity and reliability.
Where to Focus Now
If your organization hasn’t started formal readiness, now is the time to establish a roadmap. CMMC success requires aligning documentation, tools, and people.
- Conduct a gap analysis against NIST SP 800-171 controls.
- Update your SSP and Plans of Action and Milestones.
- Verify your SPRS score is current and backed by real evidence.
- Engage a C3PAO early to secure a slot before capacity runs out.
Each action builds momentum and prevents costly surprises when enforcement arrives.
Get Ahead of the Bottleneck
Defense contractors that delay CMMC readiness are heading toward the same wall: limited assessors, fixed deadlines, and lost opportunity. Early preparation buys time, flexibility, and trust.
Get ahead now before November’s rule takes effect.
FAQs
When does CMMC enforcement officially begin?
The 48 CFR rule takes effect on November 10, 2025, adding CMMC certification as a requirement for new Department of Defense contracts. Contractors should begin readiness efforts now to avoid scheduling delays with assessors.
What’s the “CMMC bottleneck” everyone is talking about?
As enforcement begins, demand for C3PAOs will grow even further. Contractors who wait to schedule assessments could face months-long delays, potentially missing bid deadlines. Learn more at isidefense.com/cmmc-bottleneck-coming.
Can I still bid on contracts without CMMC certification?
After November 10, 2025, new solicitations that include CMMC clauses will require certification at the time of award. You may still bid during the transition, but award eligibility will depend on your readiness status.
How long does CMMC Level 2 certification take?
Most contractors require 12 to 18 months for full implementation, evidence collection, and assessment. The timeline depends on your current NIST SP 800-171 posture and whether remediation is needed.
Is my SPRS score related to CMMC?
Yes. Your SPRS score reflects progress toward NIST SP 800-171 compliance, which underpins CMMC Level 2 certification. Primes use SPRS scores as an early indicator of readiness and risk. CMMC assessments validate that your SPRS score is accurate.
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