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What Happens if You Ignore CMMC in 2026?

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Executive Brief 

Cybersecurity Maturity Model Certification (CMMC) is no longer theoretical. It is contractually enforceable, auditable, and directly tied to eligibility for work from the Department of Defense (DoD) (also known as the Department of War). 

Ignoring CMMC does not typically result in an immediate fine or enforcement letter. Instead, the consequences surface where it matters most: contract awards, renewals, and subcontracting opportunities. 

Dig deeper below to learn what happens when CMMC requirements are ignored and why delaying now creates real business risk later.

CMMC: The Current Operating Reality 

CMMC requirements are actively flowing into DoD contracts under the finalized Code of Federal Regulations Title 48 rule. For most defense contractors handling Controlled Unclassified Information (CUI), CMMC Level 2 is the baseline. 

That means: 

  • CMMC is a condition of contract award, not guidance 
  • Certification status is checked before award, not after 
  • Assertions without evidence no longer pass scrutiny 

CMMC enforcement occurs at procurement, not through surprise audits. 

If you cannot meet the requirement, you are not eligible for the work. 

What Happens When You Bid Without CMMC 

The most common consequence of ignoring CMMC is quiet disqualification. 

In practice, this looks like: 

  • Your proposal is marked non-responsive due to missing certification or concrete assessment date 
  • Your bid is removed before technical evaluation 
  • You receive little or no feedback explaining why 

There is no appeal process for missing a mandatory requirement. 

Even incumbent contractors can lose option years or task orders when certification requirements are not met. 

The Prime Contractor Effect 

Even when the DoD is not the immediate enforcement point, prime contractors are. 

Prime contractors are now beginning to: 

  • Verify subcontractor CMMC status before onboarding 
  • Flow down certification requirements contractually 
  • Remove vendors that introduce compliance risk 

Technical capability and pricing no longer compensate for lack of certification. 

From a prime contractor’s perspective, a subcontractor without CMMC creates an unacceptable supply chain risk. 

Supplier Performance Risk System (SPRS) Scores Still Matter 

Ignoring CMMC often coincides with neglected or inaccurate SPRS scores. 

This compounds risk. 

Today: 

  • SPRS scores are routinely reviewed during sourcing decisions 
  • Scores must align with documented implementation 
  • Discrepancies trigger follow-up and scrutiny 

Submitting inflated or unsupported SPRS scores creates legal exposure, not just compliance gaps. 

Multiple enforcement actions tied to National Institute of Standards and Technology Special Publication 800-171 (NIST SP 800-171) misrepresentation or negligence have resulted in seven-figure settlements. 

CMMC increases visibility into these risks, it does not replace them. 

The Cost of Last-Minute Compliance 

Many organizations assume CMMC can be addressed quickly once a contract requires it. 

That assumption rarely holds. 

Common late-stage challenges include: 

  • Undefined CUI scope or environment boundaries 
  • Incomplete or outdated System Security Plans 
  • Missing or inconsistent evidence for implemented controls 
  • Limited availability of qualified Certified Third-Party Assessor Organizations (C3PAOs) and Certified CMMC Assessors (CCAs) 

Waiting often results in missed contract opportunities rather than delayed certification. 

There Is No “Wait and See” Advantage 

Ignoring CMMC does not preserve flexibility. It reduces options. 

Right now: 

  • Certification timelines are predictable 
  • Assessment expectations are standardized 
  • Prime contractors expect readiness, not intent 

Delaying compresses cost, effort, and risk into a smaller window with fewer recovery paths. 

What Smart Contractors Are Doing Now 

Organizations that remain competitive are not scrambling. They are sequencing. 

Common steps include: 

  • Confirming required CMMC level by contract and data type 
  • Scoping CUI environments to reduce assessment burden 
  • Closing high-impact NIST SP 800-171 gaps first 
  • Scheduling assessments ahead of bid deadlines 

CMMC readiness is now part of business development strategy, not a side project. 

Ignoring CMMC does not trigger dramatic enforcement. It quietly removes you from the defense marketplace. 

You lose bids before evaluation. 
You lose trust with prime contractors. 
You absorb more risk with less leverage. 

CMMC is not about punishment. It is about eligibility.

 

FAQs 

Will DoD fine us for not having CMMC?

No. CMMC enforcement does not typically involve fines or penalties issued directly by the DoD. Instead, CMMC is enforced at the contracting level. If a solicitation requires certification and you cannot provide it, your proposal is deemed non-responsive and removed from consideration. The impact is loss of eligibility, not a citation or warning. 

Can we state that we are “working toward” CMMC compliance?

 Not when CMMC compliance is required at the time of contract award. If a contract requires CMMC Level 2 certification or an authorized Level 2 self-assessment, the requirement must be met before the award is issued. Statements of intent or in-progress remediation do not satisfy a contractual requirement. That said, during pre-award discussions, subcontractor vetting, or internal planning, organizations may communicate expected certification timelines. Whether that is acceptable depends on the prime contractor or contracting officer’s risk tolerance. 

What happens if we misrepresent our CMMC or NIST 800-171 status?

Misrepresentation creates legal risk beyond contract loss. Inaccurate assertions related to NIST 800-171 implementation or SPRS scoring can trigger False Claims Act exposure. Several contractors have already faced seven-figure settlements tied to overstated compliance claims. CMMC increases visibility into these assertions, making accuracy essential. 

Can we rely on our prime contractor’s certification instead of getting our own?

Generally, no. Each legal entity handling CUI is responsible for its own compliance unless it operates entirely within the prime’s authorized and documented environment. This arrangement must be contractually defined, technically enforced, and supported by evidence. Most subcontractors still require their own certification. 

What if our contract does not explicitly mention CMMC yet?

Even when CMMC is not named, requirements often flow down through predating Defense Federal Acquisition Regulation Supplement clauses (i.e. 252.204-7012), prime contractor policies, or future task orders. Many primes now require proof of readiness or certification as a condition of doing business, regardless of current contract language. Waiting for explicit mention often results in missed opportunities. 

Can we self-assess for CMMC Level 2 instead of using a C3PAO?

Only in limited cases. Level 2 self-assessment is permitted solely for non-prioritized acquisitions and only when explicitly authorized in the contract. Most contracts involving sensitive or high-risk CUI require third-party assessment by a C3PAO. If the contract language is silent, the safest assumption is that third-party certification is required. 

Is CMMC a one-time certification?

 No. Certification must be maintained. Level 2 certifications expire after three years and require ongoing control maintenance, documentation updates, and readiness for reassessment. Treating CMMC as a one-time exercise rather than an operational program increases long-term risk. 

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