Cybersecurity Maturity Model Certification Requirements

Who must comply

Any DoD contractor or subcontractor at any tier on a solicitation or contract that includes the clause, on the phased rollout that began November 10, 2025.

What it requires

1. 01Have, at the time of award, a current CMMC certification or self-assessment at the level required by the contract for any covered information system.
2. 02Maintain the required CMMC level throughout contract performance.
3. 03Complete and post the annual senior-official affirmation in SPRS as required by 32 CFR 170.22, and keep it current for each CMMC UID.
4. 04Submit the SPRS-issued CMMC UID(s) to the contracting officer and report any changes in those UIDs through the life of the contract (paragraph (e)).
5. 05Ensure subcontractors hold, and annually affirm, the required CMMC status before subcontract award; if the contractor's own status is Conditional, close out the POA&M per 32 CFR 170.21 to reach Final.
6. 06Flow the substance of the clause down to subcontracts at all tiers that will process, store, or transmit FCI or CUI in performance of the contract (excluding COTS purchases), at the level required for the type of information the subcontractor will handle (32 CFR 170.23).

Key points

• The clause is inserted into new solicitations on a phased schedule that began November 10, 2025. On July 13, 2026, DoD suspended Phase 2 of that schedule and opened a 60 day review of the CMMC program, so the November 10, 2026 Phase 2 date is no longer an operative deadline. Phase 1, which requires a CMMC self-assessment on applicable contracts, remains in force.
• At Level 1, the required artifact is a self-assessment with an annual affirmation, no third-party assessment is involved. The Phase 2 suspension does not change this.
• At Level 2, the artifact is either a self-assessment or a C3PAO certification, depending on what the contract specifies.
• Phase 2 is paused, not cancelled. What the suspension removed is the deadline pressure, not the requirement. Where the clause is already in a contract it still binds, DFARS 252.204-7012 is unaffected, and a knowingly false affirmation carries the same False Claims Act exposure it always did.

Related clauses

• DFARS 252.204-7012
  Safeguarding Covered Defense Information and Cyber Incident Reporting

  DFARS 252.204-7012 requires DoD contractors that handle Covered Defense Information (CDI) to implement the security requirements of NIST SP 800-171, report cyber incidents to DoD within 72 hours via the DIBNet portal, and use FedRAMP Moderate (or equivalent) cloud services for CDI. It has been the contractual basis for NIST 800-171 across the defense industrial base since 2017.

• 32 CFR 170.15
  CMMC Level 1 Self-Assessment and Affirmation Requirements

  32 CFR 170.15 sets the procedural requirements for CMMC Level 1: an annual self-assessment against the 15 safeguarding requirements of FAR 52.204-21, scored on a binary MET / NOT MET basis with no POA&Ms permitted, followed by an annual affirmation posted in SPRS by the company's Affirming Official.

• 32 CFR 170.22
  Affirmation by a Senior Official

  32 CFR 170.22 requires a named Affirming Official, defined at 32 CFR 170.4 as the senior level representative responsible for ensuring the contractor's compliance with the CMMC Program requirements who has the authority to affirm its continuing compliance, to electronically affirm in SPRS at least every 12 months that the contractor continues to meet the CMMC security requirements for its level. A knowingly false affirmation is the explicit target of the Department of Justice Civil Cyber-Fraud Initiative under the False Claims Act.

Related terms

• Cybersecurity Maturity Model Certification
• Annual Affirmation
• 32 CFR Part 170
• 48 CFR CMMC Acquisition Rule

Read more in the Library

• The 48 CFR CMMC Acquisition Rule: What Changes in Your DoD Contracts (2026)

  32 CFR 170 created CMMC. 48 CFR is the rule that puts it into your contract. Here's what to look for in the next solicitation that lands in your inbox.

• The CMMC Annual Affirmation: The One Thing That Breaks DIY Compliance, 2026

  Year-one DIY CMMC is easy. Year two is where most contractors quietly lose compliance. Here's how to not be one of them.

• CMMC Level 1: The Complete 2026 Guide for Small DoD Contractors

  The single page to read first. What CMMC Level 1 is, who it applies to, what's actually required, what it costs, and the fastest honest path through it in 2026.