For years, defense subcontractors have been warned that the Department of Defense (DoD) would begin enforcing the Cybersecurity Maturity Model Certification (CMMC). Many contractors expected another extension or believed self-attestation would remain sufficient for compliance.
That era is over.
As of November 10, 2025, CMMC requirements are beginning to be written into contracts. CMMC is no longer built on trust. You are now required to provide evidence, documentation, and secure practices to demonstrate compliance.
This guide breaks down what changed, what CMMC certification actually requires, and how to prepare for compliance.
Explaining the Confusion
Many contractors understand that something has changed, but aren’t sure what it means for their systems, documentation, or eligibility to bid on future work. This is where ALLO Business helps simplify the process. We break down CMMC requirements in plain terms, outline what applies to your specific contracts, and help you prepare long before an auditor or prime contractor starts asking questions.
Early enforcement is uneven, which gives businesses a false sense of security. Some contracts already require proof of compliance, while others haven’t required proof. That inconsistency makes it easy to assume you’re not affected yet.
Even if your current contract hasn’t been updated, your prime contractor can require proof of compliance starting with your next contract. And primes are doing exactly that because they now share the liability.
For subcontractors who have never been asked about cybersecurity documentation or audits before, this is the biggest shift:
You can no longer assume you’re compliant. You must prove it.
What’s Changed
On September 9, 2025, the Department of Defense released its final CMMC rule, which became effective November 10, 2025, through implementation in the Defense Federal Acquisition Regulation Supplement (DFARS).
If you’re bidding on new DoD work today, you may already need to demonstrate compliance in your next contract.
This is now a national certification requirement.
Understanding the Three CMMC Levels
Your required level is dictated by the type of data you handle, not your company size. Higher levels include everything in the lower ones.
CMMC Level 1 – Foundational (210,000 contractors)
Handles Federal Contract Information (FCI) government data not intended for public release. Requires 17 basic practices like multi-factor authentication and regular updates. Annual self-assessment required with results posted to SPRS.
CMMC Level 2– Advanced (118,000 contractors)
Handles Controlled Unclassified Information (CUI) sensitive defense data. Requires all 110 NIST SP 800-171 security controls. If your contracts include DFARS 252.204-7012, you’re likely here. Most require third-party C3PAO certification every three years and self-attest every year.
CMMC Level 3 – Expert (3,400 contractors)
Handles the most sensitive CUI on critical defense programs. Requires 110 controls plus enhanced protections against nation-state threats. DoD conducts assessments directly every three years.
Why “Good Enough” No Longer Cuts It
This is where most contractors get blindsided.
CMMC now requires documented evidence, accuracy affirmations, and continuous compliance throughout contract performance. A senior official must sign off on the accuracy of your compliance.
Not to mention, the consequences are real. False claims can trigger:
- Contract termination
- Suspension or debarment
- DOJ investigations under the False Claims Act
- Significant financial penalties
The organizations getting hit aren’t the ones with poor cybersecurity measures. They’re the ones who can’t prove they’re doing what they claim.
A lot of organizations have the right security tools in place, but no way to demonstrate how they’re used. Think of it like having a home security system, but no footage to show it was armed. You might be protected, but you can’t prove it when it counts.
Your 5-Step Roadmap to CMMC Readiness
Step 1: Identify your required CMMC level
Review contracts for DFARS clauses and determine whether you handle FCI or CUI.
Step 2: Conduct a gap assessment
This review will provide a roadmap from where you are to where you need to be.
Step 3: Build your remediation plan
Prioritize fixes by risk and effort.
Common needs: MFA enforcement, logging improvements, written policies and procedures, and IR documentation.
Step 4: Collect and organize proof
Screenshots, configurations, logs, procedures, policies…everything must be documented.
If you can’t show it, auditors will assume it doesn’t exist. It’s like an audit where undocumented expenses simply don’t count, even if they were legitimate.
Step 5: Prepare for your assessment
Train your internal team on who answers what and how.
Preparation makes or breaks success.
ALLO Business: Your Partner for CMMC Certification Preparation
If you’re unsure where you stand or don’t have the internal bandwidth to manage compliance, ALLO Business helps contractors prepare efficiently and correctly.
We provide:
- CMMC gap assessments
- Evidence and documentation support
- Remediation guidance
- Certification preparation
- Connections to accredited C3PAO organizations
Think of us like the accountant before the IRS. We help you get everything in order so the audit is clean and accurate.
CMMC isn’t impossible. It’s just new. If you want clarity on your next steps, set up a consultation with our team for guidance!
