The Department of War’s (DoW) recent announcement on pausing the implementation of CMMC Phase II has created uncertainty across the Defense Industrial Base (DIB).
For many contractors, the immediate question is:
Does this mean CMMC preparation can be put on hold?
The answer is no.
Although the DoW has paused the timeline for mandatory Certified Third-Party Assessment Organization (C3PAO) assessments, the cybersecurity requirements that protect Controlled Unclassified Information (CUI) remain in place through DFARS 252.204-7012.
If your business handles CUI, you must continue implementing and maintaining the cybersecurity controls required to protect that information.
This pause creates a strategic advantage for contractors that act now.
Instead of racing toward a certification deadline, your organization has additional time to strengthen its cybersecurity posture, close security gaps, improve operational resilience, and prepare for future assessment requirements.
The contractors that use this time wisely will be better positioned to compete for and retain Department of War contracts when CMMC implementation resumes.
The recent announcement changes how compliance will be validated, not whether compliance is required.
Under the original rollout schedule, CMMC Phase II was expected to begin on November 10, 2026. During this phase, many contractors pursuing CMMC Level 2 would transition to third-party assessments conducted by C3PAOs.
On July 13, 2026, the DoW announced a 60-day pause while it reviews the program and evaluates ways to make implementation more scalable and achievable across the DIB.
It is important to understand what this announcement does and does not mean.
What Changed:
What Did Not Change:
The pause should be viewed as an opportunity, not a reason to delay.
A successful CMMC self-assessment requires more than you may think.
Organizations need documented processes, implemented security practices, and supporting evidence that demonstrates those practices are operating as stated.
The extra time created by the Phase II pause provides contractors with an opportunity to focus on these exact areas.
Organizations that wait until assessment requirements resume may find themselves trying to complete preparation while also competing for assessment availability.
But organizations that continue building now will have a stronger foundation moving forward.
RAMPQuest’s CMMC Progressing Pathways program helps contractors use this extension period strategically by providing the guidance, validation, and roadmap needed to continue progressing toward CMMC readiness.
Whether your organization is just beginning its CMMC journey or has already completed significant preparation, Progressing Pathways helps you understand where you stand and what steps to take next.
For contractors that have completed their documentation and gathered supporting evidence, the next step is ensuring everything is assessment-ready.
Through Progressing Pathways, CyberAB certified advisors evaluate your current cybersecurity program, identify overlooked risks, and provide actionable recommendations that strengthen your readiness before formal assessments resume.
This independent validation helps you:
Rather than waiting for a certification assessment to uncover issues, you can address them now while you still have time.
For organizations that have not yet completed their documentation or readiness efforts, this pause provides valuable time to make progress.
Progressing Pathways helps contractors:
Most importantly, the program helps you focus on implementing effective cybersecurity solutions rather than simply checking compliance boxes.
The question is not:
“Should we wait?”
The better question is:
“How can we use this time to make sure we are ready?”
Contractors who continue addressing gaps and validating their readiness today will be better positioned as CMMC requirements continue evolving.
RAMPQuest’s CMMC Progressing Pathways program helps organizations turn uncertainty into action by providing the expertise and support needed to keep moving forward.
Build momentum and be ready for what comes next.