>_ CMMC 2.0 · facts as of October 2026
CMMC readiness for the Huntsville defense industrial base.
Shrink your CUI scope, close the highest-weight gaps first, and run the evidence program that backs your affirmation. Readiness, not certification, from a firm that knows the difference.
CMMC Phase 2 begins November 10, 2026
Nov 10 2026
Level 2 C3PAO certification in applicable DoD solicitations.
- 110NIST SP 800-171 Rev 2 requirements behind CMMC Level 2
- −203 to 110Range of the SPRS score (DoD Assessment Methodology)
- 72 hoursTo report a cyber incident to DoD under DFARS 252.204-7012
- 3 yearsLevel 2 assessment cycle (self-assessment or C3PAO), with annual affirmations
>_ 01 Levels
What each level requires
| Level | Protects | Requirements | Assessment |
|---|---|---|---|
| Level 1 | FCI | 15 basic safeguarding requirements (FAR 52.204-21) | Annual self-assessment and affirmation in SPRS |
| Level 2 | CUI | 110 requirements of NIST SP 800-171 Rev 2 | Self-assessment or C3PAO certification (per contract) every 3 years, plus annual affirmation |
| Level 3 | CUI on critical programs | Level 2 plus selected NIST SP 800-172 requirements | DCMA DIBCAC government assessment, after a final Level 2 C3PAO certification |
>_ 02 Phased rollout
Where the program stands
- Phase 1 · Nov 10, 2025
Level 1 and Level 2 self-assessments required in applicable solicitations
- Phase 2 · Nov 10, 2026
Level 2 certification by a C3PAO required in applicable solicitations
- Phase 3 · Nov 10, 2027
Level 3 (DCMA DIBCAC) requirements begin
- Phase 4 · Nov 10, 2028
Full implementation across applicable contracts
DoD may include higher requirements earlier at its discretion. Sources: 32 CFR Part 170 (CMMC Program rule), DFARS 252.204-7012 / -7019 / -7020 / -7021, and DoD CIO CMMC resources. Verify current status before relying on any date.
>_ 03 Method
How a PDI readiness engagement runs
- 00 · 1 call
Qualify
FCI only, or CUI? Which contracts and flow-downs? When is the next award?
- 01 · Weeks 1–4
Scope & gap
CUI data-flow diagram, asset inventory by category, 110-requirement gap assessment, preliminary SPRS score
- 02 · Weeks 4–16
Remediate
Highest-weight gaps first (MFA, encryption, logging, access control, incident response), SSP, POA&M
- 03 · Weeks 12–24
Evidence
Monthly evidence program running, policies adopted, training records, mock assessment
- 04 · As scheduled
Assessment
C3PAO readiness review, evidence binder, support during the assessment
- 05 · Ongoing
Sustain
Evidence program, annual affirmation support, change tracking
>_ 04 Boundaries
What we don’t do
- PDI does not certify anyone. Level 2 certification comes from an authorized C3PAO; Level 3 assessments are performed by DCMA DIBCAC.
- PDI is not a C3PAO or a FedRAMP-authorized cloud provider.
- Your senior official signs SPRS affirmations. PDI prepares the evidence with you.
- Readiness work does not guarantee an assessment outcome.
- When PDI manages your security tools, PDI becomes an External Service Provider, and our people and tools are in your assessment scope. We document that shared responsibility up front.
>_ 05 Related services
Built for contractors
Compliance & vCISO work is billed at $275/h. See pricing.
Phase 2 is a calendar problem.
Assessor calendars book months out. Start the gap assessment now, so your evidence is ready before the award.