On July 13, 2026, the U.S. Department of Defense recently announced a temporary suspension of CMMC Phase 2 requirements while launching a 60-day review of the program under a newly appointed Task Force. Although the announcement has understandably created uncertainty across the Defense Industrial Base (DIB), organizations should recognize that this is a review of the certification program—not a rollback of cybersecurity requirements.
For defense contractors, the message is clear: the expectation to protect Controlled Unclassified Information (CUI) has not changed. This temporary pause provides an opportunity to strengthen your cybersecurity posture and prepare for what will almost certainly be the next phase of CMMC implementation.
The DoD has paused implementation of CMMC Phase 2 while it evaluates how the program can better achieve its intended objectives. One of the Task Force's primary goals is expected to be identifying ways to reduce the complexity and cost of compliance—particularly for small and medium-sized businesses that play a critical role in the defense supply chain.
While the certification process is under review, several important requirements remain unchanged.
Despite the temporary suspension, contractors must continue to meet existing contractual cybersecurity obligations.
Organizations that handle CUI are still required to comply with NIST SP 800-171 under DFARS 252.204-7012, and self-assessments remain in effect during the review period. The DoD has not relaxed its expectations for protecting sensitive information, nor has it suggested that cybersecurity requirements themselves are being reduced.
Simply put, the pause applies to portions of the CMMC rollout—not to safeguarding government data.
While no one can predict the exact outcome of the 60-day review, several trends are becoming apparent.
We expect the DoD to move toward a more streamlined, risk-based approach that focuses less on procedural complexity and more on measurable cybersecurity outcomes. Rather than reducing security expectations, the revised program will likely emphasize practical controls that demonstrably reduce cyber risk while making compliance more attainable for organizations of all sizes.
We also fully expect third-party CMMC assessments to return.
Although implementation dates may shift, the review appears to be intended to improve the program, not eliminate independent verification. Given the relatively short review period, revised guidance and a new implementation timeline could arrive sooner than many organizations expect.
For organizations that have been working toward CMMC compliance, this pause should be viewed as an opportunity rather than a setback.
Without the pressure of an immediate certification deadline, companies have additional time to:
Organizations that continue investing in compliance today will be significantly better prepared when the revised CMMC program resumes.
One of the biggest risks organizations face is assuming the suspension means they can postpone cybersecurity investments.
History suggests otherwise.
Once new guidance is released, demand for consultants, Registered Provider Organizations (RPOs), Certified Third-Party Assessment Organizations (C3PAOs), and assessment scheduling will likely increase rapidly. Companies that delay preparation may find themselves competing for limited resources while working against compressed timelines.
The organizations that will be in the strongest position are those that continue making steady progress now.
At Daymark Solutions, we believe this review represents an opportunity to build a stronger cybersecurity foundation, not a reason to pause compliance efforts.
We will continue helping organizations assess and improve their NIST SP 800-171 compliance, prepare for future CMMC assessments, develop practical remediation roadmaps, and implement secure Microsoft Government cloud environments that support long-term compliance objectives.
While the certification process may evolve, the mission remains the same: protecting sensitive defense information and strengthening the cybersecurity of the Defense Industrial Base.
We'll continue monitoring developments throughout the DoD's 60-day review and provide updates as additional guidance becomes available. In the meantime, organizations that continue moving forward today will be far better positioned for whatever comes next.
If you want to learn more, download our 7-Step Guide to CMMC Compliance. If you have questions or want to discuss your CMMC strategy, let’s connect.