CMMC Final Rule Deadline Update

Delaying CMMC is No Longer an Option

The Department of Defense (“DoD”) officially submitted the final 48 CFR CMMC rule to the Office of Information and Regulatory Affairs (“OIRA”) on Tuesday, July 22, 2025.

Projected Timeline – CMMC Final Rule

As mentioned above, 48 CFR CMMC will now be reviewed by OIRA, which is expected to take between 60 and 120 days to complete, though it may be completed sooner. Once the rule is approved, it will be sent to the Federal Register for publication. This process can take about one to three weeks, which will trigger the 60-day period before CMMC is required.

Impact of the CMMC Final Rule

48 CFR CMMC will invoke CMMC requirements on every subcontractor at every tier. The DoD estimates that more than 220,000 organizations will need to become CMMC compliant, with the majority falling into Levels 1 and 2.

As a reminder, Level 1 is for businesses that handle Federal Contract Information (“FCI”) and receive payment from or provide an invoice to a federal entity. Level 2 applies to organizations that handle Controlled Unclassified Information (“CUI”).

Delaying Compliance is Off the Table

Now that this significant milestone has been reached for CMMC, it’s time for contractors and subcontractors to realize that being compliant is mandatory. The pressure is on for small and mid-size companies to earn their competitive advantage in the government bidding game.

Let’s go over a few reasons why you need to start aiming for CMMC compliance now:

1. The Deadline is Fast Approaching

Despite the phased rollout, CMMC requirements will be implemented in new DoD contracts beginning 60 days after the final rule is published.

In our previous blog, we recommended dedicating at least 12 months to overall CMMC prep work. Below is a chart breaking down the approximate timelines:

2. CMMC is More Complex Than You Think

Each step of the CMMC process requires thorough documentation and execution.

From developing procedures like Standard Operating Procedures [“SOPs”], System Security Plan [“SSP”], and Plan of Action and Milestones [“POAM”] to the implementation of NIST SP 800-171 Rev. 2 (CMMC is NOT against Rev. 3), each layer is complying with one of the most demanding federal compliance frameworks.

3. CMMC Gives You a Competitive Advantage

Rather than looking at CMMC compliance as a financial liability, view it as an opportunity to stand out in a currently crowded market.

Because of the cost to achieve compliance, it’s expected that upward of 30% of companies will drop out of the running for DoD contract bids.  

How BAE Networks Can Be Your CMMC Partner

Now that 48 CFR CMMC has been handed off to OIRA, the preparation window for CMMC compliance is quickly shrinking as the timeline is more certain. When you decide to partner with BAE Networks on your CMMC journey, you gain:

Expertise in CMMC & NIST 800-171 Rev. 2

Scheduled to be Michigan’s first CMMC Level 2 Certified MSP, BAE Networks has walked through each step of the certification process.

Cost-Efficiency

You’ll gain the tools, monitoring, and expertise to protect FCI and CUI at a fraction of the cost of an internal team.

Proactive Security

24/7 network monitoring identifies vulnerabilities and detects suspicious activity before it becomes a threat.

Reduced Downtime

BAE’s remote support and incident response are available 24/7 to keep your operations running smoothly.

Scalable Support

Our IT and cybersecurity solutions adapt with your growing business’ evolving requirements to ensure long-term protection.

If you haven’t started working toward your certification, this is your sign. Contact a turn-key CMMC partner, like BAE Networks, today to get closer to the competitive edge you need in the aerospace and defense space.