Article

CMMC Level 2 in 2026: Why Contractors Need to Engage a C3PAO Now

December 15, 2025

As the Defense Industrial Base moves into the first full year of CMMC enforcement, it is becoming increasingly clear that organizations that act early will move through assessment with less disruption. With demand rising and the number of authorized assessors limited, 2026 will reward contractors who secure their assessment window now.

Demand Outlook: Thousands Still Need Assessments

The number of contractors pursuing CMMC Level 2 assessments continues to surge. Many waited through 2025 for additional clarity or internal readiness.  That wave is now converging with organizations contractually required to validate compliance early in 2026.

The result is a sharp increase in demand for Level 2 assessments at a time when C3PAO capacity remains limited. Early engagement is quickly becoming the only reliable way to secure an assessment window and maintain eligibility for CUI-driven work.

Lessons Learned From 2025 

Across the industry and reflected in our own assessment observations, several themes defined 2025.

The readiness gap remained significant.

According to a 2025 report surveying DIB contractors, only 46% said they were prepared for Level 2 certification (1). This lack of readiness puts organizations at risk of being unable to bid on or win DoW contracts where CUI is involved.

Documentation, scoping, and evidence gaps were the most frequent causes of delays or failed audits.

According to an analysis of C3PAO-reported findings in 2025, the most frequent pitfalls were incomplete or missing documentation (2). This proves that assessment readiness relies on organization, evidence, and clarity, something many contractors underestimated when preparing in 2025.

Assessment capacity constraints create real scheduling risks.

The number of C3PAOs remains limited, and backlogs have reportedly stretched into 2026 for many organizations (3). Late starters are facing longer wait times, potentially risking contract eligibility or delaying bids. This bottleneck has turned assessment scheduling into a strategic decision, not just a compliance checkbox.

These lessons from 2025 demonstrate how contractors who wait to involve their assessors struggle the most with readiness gaps, documentation issues, and scheduling bottlenecks.

Early Engagement Reduces Friction and Cost

Engaging a C3PAO early allows contractors to structure their assessment timeline intentionally rather than reactively. This provides several advantages:

  • Scheduling certainty during periods of peak demand
  • Early identification of gaps that can be resolved without driving costs or delaying critical contract pursuits
  • A smoother assessment experience, with ample time to compile, validate, and organize evidence

Early engagement reduces both friction and cost while increasing likelihood of an efficient, disruption-free assessment.

Our Experts Are Prepared for Growing Demand

As an authorized C3PAO, Coalfire Federal approaches 2026 with a purpose-built CMMC assessment team, a proven methodology, and a track record of delivering predictable, high-confidence assessments for contractors. With increased demand expected throughout 2026, our team is prepared to support organizations that engage early. 


Contractors who move now will be positioned more competitively in 2026. If your organization anticipates a Level 2 assessment in 2026, now is the time to lock in your assessment window. Connect with our team of experts today.

 

References

  1.  https://www.cmmc.com/newsroom/dib-readiness-for-cmmc-in-2025
  2.  https://alluvionic.com/state-of-cmmc-2025-what-c3paos-are-saying-about-certification-readiness
  3.  https://www.forbes.com/sites/heatherwishartsmith/2025/11/17/the-cmmc-assessor-shortage-is-the-new-federal-contracting-bottleneck