Beginning on November 10th, cybersecurity compliance through CMMC is no longer optional. However, at least one survey reports that nearly half of all affected organizations claim they’re not prepared despite a multi-year run-up to this point. Here’s a closer look, and what to do if you’re one of those unready contractors:
What Changes in November?
Starting November 10, contracting officers may include CMMC clauses in any new solicitations, tying eligibility to a contractor’s CMMC status. But even before full enforcement, self-assessment requirements will be required for Level 1 and some Level 2 contractors. This November milestone marks the start of a phased rollout that will stretch into 2028. Over this period of time, CMMC clauses will become the norm in almost all DoD contracts.
Not Ready? Here’s how to start:
Determine your scope and target level. Step One is to identify whether your organization handles Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), and which CMMC level (1, 2, or 3) applies.
Get a baseline readiness assessment. Conduct or hire a third party to do a “gap assessment” to see where you currently fall short. This vital step will identify the specific road map to CMMC compliance for your organization.
Prepare documentation. Create or update your System Security Plan (SSP), policies, procedures, and evidence repository aligned with CMMC requirements. This too may require qualified third-party help.
Do it now. Especially for levels 2 and 3, assessment slots are in high demand. Engage expert help as early as possible to avoid long delays.
Plan remediation. While compliance for some critical controls can’t be deferred, there may be some lesser standards you’re not prepared to meet immediately. In these cases, a Plan of Action and Milestones (POA&M) can demonstrate timelines for closure within the allowed 180 days.
Consider lean enclaves. For many organizations, lean enclaves can provide a less-disruptive path to CMMC compliance. In short, a lean enclave isolates and addresses only the relevant portions of your overall IT footprint. This can often save a good deal of time and expense. (More on lean enclaves in our recent post.)
Find the right CMMC partner. There are an ever-growing list of solutions and companies offering CMMC services, and it can be hard to tell them apart. The most important thing is to find a partner that focuses on readiness and implementation, not just paperwork or passing an audit.
Look for a company with certified CMMC professionals on staff who have done this before. Experience matters. You want someone who understands what is required for CMMC and knows how to apply it in a way that fits how your business operates. A good partner helps shape CMMC around your workflows and goals, not the other way around.
The goal should never be to simply check boxes. The goal should be to build a stronger, more secure company that protects your data and the information you manage for others. In the end, that stronger security helps keep our men and women on the frontlines safer as they do their jobs.
The looming November 10 date is much more than symbolic; it jolts CMMC from a long-discussed theory to enforceable reality. If you aren’t ready by then, you risk disqualification from new DoD opportunities. Start your assessments now, engage the right partners, and build your remediation plan. The deadline is firm, but it’s not too late.
Questions about CMMC compliance? Contact Hill Tech Solutions.
