EMERGENCY ALERT: CMMC Final Rule Submitted — Enforcement Imminent

The countdown has begun. No certification, no contract.

Let’s be blunt: if your organization supports the Department of Defense and you haven’t locked in your CMMC readiness, you’re in trouble.

The final rule is under review. Enforcement is coming fast. And when it hits, the gap between “we meant to” and “we’re compliant” will be the difference between landing a contract—or getting blacklisted.

On July 22, 2025, the Department of Defense submitted the final CMMC rule (DFARS Case 2019-D041) to the Office of Information and Regulatory Affairs (OIRA)—the last stop in the federal rulemaking process.

No more drafts. No more delays. No more grace.

Once OIRA signs off—and they will—the rule will be published in the Federal Register and become enforceable under Title 48 CFR. Based on typical timelines, enforcement could begin as soon as November or December 2025.

Let’s clear something up:

If someone says, “Don’t worry, it’s not until October 1st”—they’re wrong.
That was CMMC 1.0. It’s outdated.

Under CMMC 2.0, DoD contracting officers are instructed to insert DFARS clause 252.204-7021 into all applicable contracts.

Once the rule goes live, every covered contract will require proof of certification. And without it—you’re out.

WHAT HAPPENS NEXT

You won’t be allowed to bid, win, or renew DoD contracts without the right CMMC level.
If you handle Controlled Unclassified Information (CUI), you’ll need a C3PAO to assess and certify.
If your NIST SP 800-171 score isn’t posted in SPRS, you’re already out of compliance.
No self-attestation for Level 2.
No waiting period.
No fallback plan.

WHO’S ENFORCING THIS?
Everyone.

DoD Contracting Officers will block your award.
DCMA will audit your program post-award.
The Cyber AB is monitoring the C3PAO ecosystem.
The DOJ is armed with the False Claims Act.
Your prime contractor will cut you loose to protect themselves.
Your MSP won’t save you.
There will be no exemptions for small businesses.
“Almost compliant” means noncompliant.

WHAT TO DO NOW – BREAK GLASS

Post your SPRS score.
Finalize your System Security Plan (SSP).
Close every POA&M—or lock in airtight documentation.
If you handle CUI, schedule a C3PAO assessment now.
Review all vendors—especially your MSP.
Get your leadership aligned.

This is survival, not convenience.

WHAT THIS DOES NOT MEAN

It does not mean you can wait for your next contract.
It does not mean good intentions buy time.
It does not mean partial compliance is enough.
It does not mean your prime will cover for you.
It does not mean you can fake it and hope.

They will check.
They will report.
And the fallout will be immediate.

CMMC is a hard gate. No cert, no contract. Period.

Final rule expected fall 2025.
Enforcement likely before year’s end.
Every new award. Every option year. Every task order.
CMMC will be mandatory.

If you’re not ready:
Your pipeline freezes.
Your subs walk.
Your reputation tanks.

You’re out—until you fix it.

This is not a wake-up call.
This is the storm.
And it’s already overhead.

Need help getting ready? We’re here.

Cyber Defense Advisors works with defense contractors across the country to navigate CMMC requirements and pass assessments with confidence.

Whether you’re just getting started or racing to the finish line, we can help you get across it.

Don’t wait.

EMERGENCY ALERT: CMMC Final Rule Submitted — Enforcement Imminent