CMMC Final Rule Clears Review — What Phase 1 Means for Defense Contractors

The Department of Defense’s CMMC 48 CFR final rule has cleared regulatory review, the final hurdle before publication in the Federal Register. Once published, CMMC Phase 1 will officially begin, and CMMC requirements will appear in Department of Defense solicitations and contracts.

This milestone is more than procedural. It marks the transition from anticipation to implementation, where certification will determine eligibility to compete in the defense marketplace.

 
Why This Matters

Clearing review does not yet make the rule effective, but it does signal certainty. CMMC will move forward. Once publication occurs, contracting officers will have explicit authority to include CMMC requirements in both solicitations and awarded contracts.

For the defense industrial base (DIB), this means:

• Certification will determine eligibility. For contractors handling controlled unclassified information (CUI), CMMC Level 2 certification through a third-party assessment is expected to be mandatory for the vast majority.
• Primes must oversee subcontractors. Certification is a supply chain responsibility, not just a prime requirement.
• Compliance becomes a competitive factor. Certified contractors will stand apart in the bidding process, while uncertified firms may find themselves locked out of opportunities.

 
Industry Implications

• Timing pressures are real. There is now a short but meaningful window between rule clearance and contract enforcement.
• Assessment capacity is finite. Accredited C3PAOs are limited, and demand will increase as Phase 1 begins.
• Readiness levels vary. Contractors that moved early will gain competitive advantage, while others may face delays.
• The end of speculation. The program is no longer in question. CMMC will be embedded in defense contracts.
   
   

Coalfire and Coalfire Federal: Securing the DIB 

This milestone is where the distinct but complementary roles of Coalfire and Coalfire Federal come into sharp relief:

Coalfire (Advisory): Helps contractors prepare for certification with readiness services, gap analysis, and compliance program support. Learn more about Coalfire’s CMMC advisory services.

Coalfire Federal (Assessment): As an accredited C3PAO, conducts impartial third-party assessments required under CMMC. Coalfire Federal does not assess Coalfire advisory clients, ensuring full compliance with impartiality requirements. Explore Coalfire Federal’s CMMC assessment services

By keeping advisory and assessment functions separate, Coalfire and Coalfire Federal together provide the defense industrial base with clarity, capacity, and trust during this critical transition.

 
The Bottom Line

With the CMMC final rule now cleared for publication, the path is set for Phase 1 and for CMMC requirements to appear in contracts. Contractors face an inflection point: eligibility to compete for defense contracts will soon depend on certification.

CMMC is no longer a future consideration. It is becoming a present requirement.

CMMC certification will soon determine eligibility in the defense marketplace. Whether you are preparing your program or ready to certify, now is the time to act. Whether you are just beginning your journey or ready for certification, we can help.  Reach out to talk to an expert today.