CMMC Phase 1 kicked off on November 10th. The Defense Industrial Base (DIB) has officially transitioned from anticipation to active verification.
Contractors spent years preparing, but the start of Phase 1 represents a definitive shift in expectations, performance, and accountability. The requirement is no longer optional. Certification activity is underway across the market, and organizations are now feeling the first operational effects of the new model.
For months, we have been forecasting this transition. Our guidance repeatedly stressed that Phase 1 would bring tighter scrutiny, increased scheduling pressure, greater documentation expectations, and higher dependency on assessor validation.
Those predictions are playing out in real time.
Phase 1 eliminates all remaining gray area around self-attestation. Contractors must now demonstrate compliance through validated evidence and implemented controls. Intent, effort, or partial documentation no longer carry weight. Assessors are now solely focused on what is implemented, not what is planned. Organizations with clear evidence trails are progressing quickly; those with incomplete implementations are entering prolonged review cycles.
Across our assessments, we continue to see recurring issues: Documentation reflects intent but not execution, policies don't match operations, and CUI scope definitions are vague. Phase 1 amplifies the importance of concise, accurate, and aligned artifacts. Generic materials will face immediate delays and potential findings.
Demand for assessment dates surged the moment Phase 1 took effect, driven heavily by prime integrators validating their supply chain. Assessment capacity remains limited, especially among high-quality C3PAOs. Contractors without confirmed dates risk entering Q2 and Q3 without a viable certification path. Finalize your scoping and secure your window now.
The clarity of the CUI boundary remains the single most consistent predictor of assessment success. Assessors are spending significant time validating boundary decisions and diagrams. Contractors who completed thorough boundary analysis earlier are experiencing shorter evidence cycles. Those with unclear or overly broad boundaries are facing increased review effort.
Primes are now demanding proof of scheduled assessments, robust NIST 800-171 implementation, and accurate CUI scope statements from their subcontractors. This trend will intensify. Contractors who move early will secure a competitive advantage and may become preferred suppliers.
The DIB is dividing:
As an active C3PAO, our responsibility is to deliver assessments with clarity, consistency, and impartiality. The content we publish reflects what we observe on the assessment frontline. Contractors now require accurate guidance, predictable assessments, and partners who understand the operational realities of Level 2 certification.
CMMC is now active. You are being evaluated against validated controls, not expectations. Those who are just beginning will need discipline and accuracy to navigate the new environment.
Coalfire Federal will continue to provide insight that reflects what assessors are seeing, what contractors are experiencing, and what the DIB needs to know as Phase 1 accelerates.
Certification is now a requirement. Evidence is now a standard. Phase 1 has begun, and the landscape is shifting quickly. If you need help on your CMMC compliance journey, reach out to us today.