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CMMC Phase I Requirements During the Phase II Pause: What Defense Contractors Must Still Do
Practical guide
CMMC Phase II is paused, but CMMC Phase I requirements remain in place. Defense contractors may still need Level 1 or Level 2 self-assessments, current SPRS records, annual affirmations, accurate assessment scopes, and continued protection of FCI and CUI.
The transition to CMMC Phase II has been suspended, but CMMC Phase I requirements remain firmly in place.
That is the most important distinction defense contractors need to understand following the Department of War’s July 13, 2026 announcement.
The Department suspended the Phase II implementation milestones that were scheduled to begin on November 10, 2026. It did not cancel CMMC, eliminate Phase I self-assessments, or remove contractors’ existing obligations to protect Federal Contract Information and Controlled Unclassified Information.
According to the Department’s official announcement, all Phase I self-assessment requirements remain active while the Department conducts its review of the program. The Department also plans to continue cybersecurity enforcement through NIST SP 800-171 Revision 2 self-assessments and selected government-led assessments.
CMMC Phase I requirements may require a contractor to complete either a CMMC Level 1 Self or CMMC Level 2 Self assessment, depending on the information processed, stored, or transmitted during contract performance.
Level 1 Self assessment generally applies when a contractor information system handles Federal Contract Information. Level 2 Self assessment generally applies when a contractor-owned information system handles Controlled Unclassified Information.
Applicable contractors must establish the correct assessment scope, complete the required self-assessment, submit results in the Supplier Performance Risk System, maintain the required CMMC status, and submit affirmations of continuous compliance. Existing FAR, DFARS, NIST SP 800-171, CUI safeguarding, incident-reporting, and subcontract flowdown obligations may also continue to apply.
The terms sound similar, but they describe two different parts of the CMMC program.
CMMC Phase I refers to the first stage of the Department’s contractual implementation schedule.
CMMC Level 1 refers to the cybersecurity level associated with basic safeguarding of Federal Contract Information.
CMMC Phase I began on November 10, 2025. The Department is currently paused within that implementation phase while it reviews the program. During this period, applicable procurements may use CMMC Level 1 Self-assessment or CMMC Level 2 Self-assessment requirements rather than the Phase II third-party assessment requirements that were scheduled to expand in November 2026.
Understanding that difference prevents two common mistakes:
Under the current official guidance, CMMC Phase I requirements can include either Level 1 Self-assessment or Level 2 Self-assessment, depending on whether the contractor system will handle FCI or CUI.
The required CMMC level should be identified in the applicable solicitation and resulting contract.
During Phase I, the Department’s stated intent is to use:
The Department’s current FAQ makes clear that a company handling only FCI does not need an independent assessment but may require a Level 1 self-assessment. When CUI is handled in contractor-owned systems, the applicable Phase I requirement is intended to be Level 2 Self rather than an independent C3PAO assessment.
Contractors should not determine their required level from assumptions, marketing materials, or the general sensitivity of a project.
Review:
The presence of CUI in one program does not necessarily place every company system within the same CMMC scope. The required CMMC status and assessment scope must correspond to the systems actually used for contract performance.
Protected information: Federal Contract Information
Security standard: 15 requirements from FAR 52.204-21
Assessment frequency: Annually
Affirmation: After the assessment and annually
Results submitted to: SPRS
POA&Ms: Not permitted
Protected information: Controlled Unclassified Information
Security standard: 110 requirements from NIST SP 800-171 Revision 2
Assessment frequency: Every three years
Affirmation: After the assessment and annually thereafter
Results submitted to: SPRS
POA&Ms: Permitted only under limited conditions and subject to a 180-day closeout period
These distinctions are summarized on the official Department of War CMMC overview and established in 32 CFR Part 170.
CMMC Level 1 Self-assessment is designed to verify basic safeguarding of FCI.
Federal Contract Information generally includes nonpublic information provided by or generated for the Government under a contract to develop or deliver a product or service. It does not include information that the Government has made public or simple transactional information used to process payments.
The official definition and safeguarding requirements are contained in FAR 52.204-21.
CMMC Phase I requirements for Level 1 are based on the 15 safeguarding requirements contained in FAR 52.204-21.
These requirements address areas such as:
A contractor cannot obtain Final Level 1 Self status while leaving one or more requirements unresolved.
Before completing the assessment, the contractor must identify the systems that process, store, or transmit FCI.
The Level 1 scope should consider the relevant people, technology, facilities, and external service providers within the company’s environment. Systems that do not process, store, or transmit FCI may be outside the Level 1 scope.
The scope should be based on how FCI actually moves through the business—not simply on a list of computers owned by the company.
The contractor evaluates its own implementation of the Level 1 requirements.
Every applicable requirement must receive a MET result. CMMC Level 1 does not use a partial numerical score in the same way as Level 2. The organization must satisfy all applicable Level 1 requirements to achieve Final Level 1 Self status.
The results of the Level 1 self-assessment must be submitted to the Supplier Performance Risk System (SPRS).
SPRS is also used by the Department to verify the company’s CMMC status and assessment information for applicable procurements.
An affirming official must attest to the organization’s continuing compliance after the Level 1 assessment and annually thereafter.
The affirmation should not be treated as a routine administrative signature. The affirming official is representing that the organization continues to satisfy the applicable security requirements.
Plans of Action and Milestones are not permitted for CMMC Level 1.
A company cannot obtain a Level 1 CMMC status by identifying incomplete requirements and promising to correct them later. All 15 requirements must be satisfied.
CMMC Level 2 Self-assessment is intended for applicable contractor systems that process, store, or transmit CUI.
During the current Phase II pause, the Department states that Level 2 Self may be required when CUI will be handled in contractor-owned information systems.
Level 2 is based on the 110 security requirements in NIST SP 800-171 Revision 2.
These requirements cover 14 security families:
The Department’s current FAQ confirms that Revision 2 remains the assessment standard during the interim period while Revision 3 awaits future incorporation through rulemaking.
CMMC Phase I requirements do not apply automatically to every asset owned by the company.
The contractor must identify and categorize the assets within the Level 2 assessment environment.
The official scoping rule identifies categories including:
CUI assets process, store, or transmit CUI. Security protection assets provide security functions or capabilities to the CMMC environment. Other asset categories have separate documentation and assessment treatment.
The organization should document its asset inventory, network diagram, System Security Plan, external service providers, and the systems used to protect CUI.
The organization must conduct its Level 2 self-assessment using the applicable CMMC procedures and scoring methodology.
The assessment results submitted to SPRS include information such as:
Level 2 self-assessments are generally valid for three years, but the organization must also complete the required annual affirmations.
The System Security Plan is central to Level 2 readiness.
It should accurately describe:
The Department’s current FAQ warns that the absence of an up-to-date SSP can result in the assessment being incomplete and the organization receiving no CMMC score.
Unlike Level 1, Level 2 can allow limited use of a POA&M.
However, not every requirement is eligible. Certain critical requirements cannot be placed on a POA&M, and the assessment must meet the applicable minimum conditions for a Conditional Level 2 Self status.
When conditional status is obtained, all eligible unresolved items must be remediated and successfully closed within 180 days. If the POA&M is not closed within the required period, the conditional status expires.
To support contract eligibility where Level 2 Self is required, the contractor must have the appropriate current CMMC status and affirmation in SPRS.
Affirmation is required at the time of the assessment and annually thereafter.
A three-year assessment cycle does not mean the organization can ignore compliance for three years. Annual affirmation requires the company to confirm that it continues to satisfy the applicable requirements.
The CMMC requirement should appear in the solicitation.
DFARS 252.204-7025 allows the solicitation to identify the required level as:
During the current Phase II pause, the Department has limited implementation to the self-assessment levels.
When a CMMC requirement is included, the applicable status is required before award for each contractor information system that will process, store, or transmit FCI or CUI during contract performance.
The offeror must have:
The contracting officer can use those identifiers to verify that the systems proposed for contract performance are covered by the appropriate CMMC status.
CMMC Phase I requirements do not replace the underlying contract clauses that require contractors to safeguard federal information.
FAR 52.204-21 requires basic safeguarding of covered contractor information systems that process, store, or transmit FCI.
These obligations can apply independently of the timing of a CMMC assessment.
DFARS 252.204-7012 establishes safeguarding, cloud-service, cyber-incident reporting, evidence-preservation, and subcontract flowdown obligations for covered defense information.
The Department’s CMMC guidance specifically states that the Phase II pause does not eliminate companies’ responsibilities under DFARS 252.204-7012.
DFARS 252.204-7019 can require an offeror to have a current NIST SP 800-171 DoD Assessment score in SPRS.
DFARS 252.204-7020 addresses Government access for Medium or High assessments and includes requirements involving applicable subcontractors.
Contractors should not assume that the CMMC Phase II pause removed these separate contract requirements.
CMMC readiness is not limited to networks, cloud systems, and cybersecurity software.
CUI can also exist in:
Organizations must protect hard-copy CUI even when the CMMC assessment requirement is focused on contractor information systems.
The Department’s current FAQ states that organizations handling only hard-copy CUI may not require a third-party assessment, but they remain obligated to safeguard that information when applicable contract clauses are included and flowed down. It specifically points contractors to NIST SP 800-171 and DoDI 5200.48 for applicable protection and handling requirements.
Physical implementation may include:
CUI Supply offers CUI Compliance Packs, CUI signs, and CUI labels that can support documented marking and physical-handling procedures.
These products support the execution of a compliance program but do not independently create CMMC status or satisfy every security requirement.
Contractors must evaluate cloud providers, managed service providers, managed security service providers, and other external organizations that support the CMMC environment.
When a cloud service provider processes, stores, or transmits CUI, DFARS 252.204-7012 requires the contractor to ensure the service meets the applicable FedRAMP Moderate requirements or approved equivalency conditions.
The Department’s official FAQ also explains that MSPs and MSSPs can be within an organization’s assessment scope when they process CUI or provide security functions for the environment, even when the provider does not need a separate CMMC certification of its own.
Contractors should document:
Outsourcing IT does not outsource the contractor’s responsibility for meeting applicable CMMC Phase I requirements.
The pause affected the expansion of independent certification requirements.
During the announced suspension, program managers and requiring activities are permitted to use Level 1 Self or Level 2 Self requirements. They may not designate Level 2 C3PAO or Level 3 DIBCAC assessment requirements during the suspension period.
The Department is also conducting a review intended to examine program burden, scalability, assessment consistency, implementation, and support for small and nontraditional businesses.
The following did not automatically disappear:
Contractors should continue reviewing each solicitation, contract, and subcontract individually rather than relying on a generalized interpretation of the pause.
Defense contractors can use this checklist to evaluate their current position:
The official CMMC FAQ recommends that businesses prepare by carefully self-assessing their contractor-owned systems, identifying unmet requirements, correcting gaps, and fully implementing the necessary security measures.
The Department’s announcement provides contractors with additional time before the wider expansion of third-party certification requirements.
It does not provide permission to stop protecting FCI or CUI.
CMMC Phase I requirements remain part of applicable procurement and contract decisions. Contractors may still need current self-assessment results, accurate assessment scopes, SPRS records, CMMC UIDs, annual affirmations, and evidence that security requirements are implemented.
The companies in the strongest position will be those that use the pause to improve accuracy rather than simply delay activity.
That means knowing:
The deadline may have changed. The responsibility to safeguard federal information has not.
Yes. The Department of War has explicitly stated that all Phase I self-assessment requirements remain firmly in place during the Phase II suspension.
Applicable procurements may require CMMC Level 1 Self or CMMC Level 2 Self assessments. During the current suspension, Level 2 C3PAO and Level 3 DIBCAC requirements may not be designated.
No. Level 1 is designed around basic safeguarding of FCI. CUI handled in contractor-owned information systems generally aligns with CMMC Level 2 requirements.
A Level 1 self-assessment is required annually, along with the required affirmation of continuous compliance.
A Level 2 Self assessment is generally required every three years. An affirmation of compliance is required at the time of assessment and annually thereafter.
POA&Ms are not permitted for Level 1. Limited POA&M use is permitted for Level 2 when all applicable conditions are met, and successful closeout is required within 180 days.
Applicable contractors may still need current NIST SP 800-171 DoD Assessment information under DFARS 252.204-7019 and 252.204-7020. Contractors subject to CMMC Phase I requirements must also submit the applicable CMMC self-assessment and affirmation information in SPRS.
No. The Department’s official CMMC guidance states that the pause does not eliminate the requirement to protect information in accordance with DFARS 252.204-7012.
Yes. Contractors and subcontractors remain responsible for protecting hard-copy CUI under applicable contract and safeguarding requirements, even when a particular paper-only environment does not require a third-party CMMC assessment.
All external references below are official United States Government or military sources:
This article is provided for general educational purposes and is not legal, contractual, cybersecurity, or certification advice.