CMMC 60-Day Countdown: What Defense Contractors Must Do Before November 10th

CMMC 60-Day Countdown: What Defense Contractors Must Do Before November 10th

The Department of Defense’s new CMMC (Cybersecurity Maturity Model Certification) requirements are approaching fast. With less than 60 days until the November 10th deadline, defense contractors need to be proactive. This article breaks down the relevant 48 CFR rule, explains why the November deadline matters, and outlines concrete steps contractors must take now to remain eligible for DoD contracts.

What Is the 48 CFR Rule & Why It Matters

The 48 CFR rule refers to the Code of Federal Regulations section governing defense contracting requirements, particularly those related to safeguarding Controlled Unclassified Information (CUI). Under the updated rule, contractors must meet certain cybersecurity practices mandated by the CMMC framework—mapped into contract clauses.

• It formalizes cybersecurity expectations into contractual obligations.
• Failure to comply means no award or continued eligibility for DoD contracts.
• The rule covers incident response, access control, risk management, and more—in line with CMMC level requirements.

Why the November 10th Deadline Is Critical

• Contract Awards Halt Unless Certified: Contracts that include CMMC requirements will not be awarded to contractors that haven’t met the required level by the deadline.
• Subcontract Impact: Even subcontractors must comply, or primes may be forced to drop them or risk non‐compliance themselves.
• Audits & Oversight Intensify: Agencies will begin enforcing these rules more strictly—expect spot audits, reviews of security posture, and demands for proof of compliance.

How Contractors Can Prepare Before the Deadline

Here are concrete steps defense contractors should take immediately to align with CMMC rules and 48 CFR requirements:

1. Conduct a gap assessment: Compare current cybersecurity measures against CMMC level required for your contracts (Level 1, Level 2, etc.). Identify missing controls in policies, technologies, and documentation.
2. Prioritize controls tied to 48 CFR clauses: Focus on access control, audit logging, incident response, physical protection, and personnel security—areas most frequently assessed.
3. Implement policies & procedures: Ensure that required documentation—security plan, incident response plan, system security plan, etc.—is in place and aligns with contract clauses.
4. Train employees: Provide training on CUI handling, phishing awareness, security hygiene, and incident reporting protocols.
5. Fix critical vulnerabilities: Patch known software flaws, remove obsolete systems, enforce strong passwords and MFA, and secure remote access.
6. Monitor & document ongoing compliance: Keep detailed logs, track changes, and be ready to produce evidence for audits. Use internal reviews to catch lapses.

Staying Eligible for DoD Contracts

Ensuring eligibility isn’t just about ticking boxes—it’s about demonstrating readiness and continuous adherence. Contractors should:

• Engage with a certified CMMC Third-Party Assessor Organization (C3PAO) early to begin the formal certification process.
• Update bids and contract templates to include proof of CMMC level compliance or evidence that gaps are being remediated.
• Leverage resources—templates, frameworks, and guidance published by DoD and industry groups—to conserve time and ensure consistency.
• Budget for certification costs, remediation work, and ongoing maintenance to avoid surprises.

Did you know?

Non-compliance with 48 CFR cybersecurity clauses doesn’t just block contract awards—it can also trigger False Claims Act liability if contractors misrepresent their security posture.

Conclusion

November 10th isn’t far away. For defense contractors, the 48 CFR rule and CMMC certification are no longer future concerns—they’re current prerequisites. By assessing gaps, prioritizing key controls, training staff, and staying well‐documented, you can protect your eligibility for DoD contracts and reduce the risk of last‐minute failures or non‐compliance.

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