CMMC Certification Process and Timeline

last changes: 08/31/2025

CMMC Timeline of Rollout

Since publication of the initial version of CMMC v1.0 in January 2020, the Certification Process and Timeline underwent many changes and experienced delays over the last years – leaving many to doubt if CMMC requirements will aver be rolled out.
But this has come to an end.
The assessments on a voluntary basis for early adopters started end of August 2022. These early assessments were joint assessments of a C3PAO with the DCMA (Defense Contract Management Agency) which oversees the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). These joint assessments performed by DIBCAC and a C3PAO are “High Confidence Assessments” (DFARS 252.204-7012 and NIST SP 800-171) and the resulting score were entered into SPRS. Once the CMMC rulemaking process was complete, the DoD to convertes those assessments with a perfect score into CMMC Level 2 certifications.

CMMC 2.13 – The Final Version

The current version, CMMC 2.13, became effective December 16th, 2024, representing a significant streamlining from the original five-level CMMC v1.0 model. This final version aligns requirements with existing NIST SP 800-171rev2 obligations that have been contractually mandated since January 2018 under DFARS 252.204-7012. CMMC Level 2 certifications by C3PAOs started in Q1 2025 on a voluntary basis.

Historic Endorsement

Secretary of Defense Lloyd Austin provided unprecedented support in July 2025, formally endorsing the program and stating that “the DoD CIO will leverage efforts such as the Cybersecurity Maturity Model Certification” to fortify the Defense Industrial Base.

CMMC Implementation Timeline – Current Status

The CMMC program has reached its final implementation phase. On August 25th, 2025, the 48 CFR final rule officially cleared regulatory review, marking the end of the lengthy rulemaking process that began with CMMC v1.0 in January 2020.

When Will CMMC Requirements Show up in Contracts?

Current Timeline (September 2025) The regulatory review process of the Title 48 CFR which will put DFARS 252.204-7021 (The CMMC Clause) into contracts concluded well under the 90-day limit, and very little remains before the rule takes effect:
  • Within the next week: The rule will be published in the Federal Register
  • 1-60 days after publication: The effective date kicks in, beginning Phase 1 of the CMMC phased rollout
  • From the effective date forward: Every new DoD solicitation and contract will include CMMC requirements—no exceptions

Timeline for CMMC requirements 2025

The CMMC Certification Process – Who Is Involved?

The CMMC eco-system is always evolving and has a lot of moving parts. Based on the CMMC level your company will need to achieve, you will either have to prove CMMC compliance through a self-assessment or you will be assessed and certified by a 3rd party organization or DoD officials. For details see CMMC Compliance Levels and Requirements in CMMC 2.0.

Your organization’s CMMC implementation timeline will depend on your current NIST SP 800-171 compliance status and the level you will need to achieve. If you will be required to become CMMC certified (CMMC Levels 2 (partially) and 3), a few organizations are relevant. The main parties involved and their focus are summarized in the diagram bellow. The CMMC Accreditation Body (CMMC-AB) is authorized by the US Department of Defense to be the sole authoritative source for the operationalization of CMMC Assessments and Training with the DOD contractor community. This organization rebranded in June of 2022 and is now called The Cyber AB.

Timeline for CMMC requirements if published as Proposed Rule

On the way to certification there are two main type of organizations that you will encounter. Both are trained and registered/certified by The Cyber AB:

  • CMMC Registered Practitioner Organizations™ (CMMC-RPO) like Ecuron are focused on consulting and help with all the steps until the certification assessment. This includes an initial CMMC gap analysis, followed by remediation and implementation of missing controls, developing documentation etc. Prior to the certification audit by a C3PAO it is recommended to perform a CMMC Pre-Assessment.
  • CMMC Third Party Assessor Organizations™ (C3PAO) are focused on the CMMC Assessment (aka Certification Audit). They will report their findings to The Cyber AB which will award you the certification if applicable. While C3PAOs are able to provide all services that CMMC-RPOs provide, they cannot provide those services to a company they will assess. This would be a clear conflict of interest.

The CMMC Certification Process – The Different Phases

Achieving CMMC compliance for your organization can be broken down into four phases:

CMMC Compliance Process - the 4 Phases to CMMC Compliance

CMMC Certification Timeline – An Example

Each organization, scope, implementation, and certification is different as it depends on a variety of parameters that determine timeline and cost. Among the main factors are:

  • CMMC Level required.
  • Existing infrastructure and cybersecurity posture of the DoD contractor
  • Number of locations in scope
  • Availability of the C3PAO to perform the Certification Assessment.

While timing is influenced by these factors, the following general example of the CMMC implementation timeline and the CMMC certification process will give you a good overall idea about the steps involved and some time estimates.

Pre-Certification Phase

2 weeks with 2-3 days on location

CMMC Gap Analysis

Identify business objective

Perform Gap Analysis: Current State vs. Requirements.
Some items evaluated include:

  • Internal structures
  • Controls and processes
  • Documentation
  • Physical Security

Implementation

Implementation

We work with the organization to implement CMMC requirements. This includes:

  • Development of missing documentation
  • Implementation of required controls
  • Identification and management of risk
  • Fix any other gaps revealed during the analysis phase.

The time required for this phase usually ranges from 2-4 months (CMMC Level 1) to 10-18 months (CMMC Level 2) although this is highly dependent upon the organization and its existing information security posture. Expect that CMMC Level 3 will require at least 18 months for implementation.

Observation / State of Readiness

Observation / State of Readiness

The CMMC Levels higher than 1 require proof of maturity of the system. Hence, after the implementation phase there will be time required to generate appropriate log files and other proof that the required controls are not just implemented but are monitored and working. Typically, this phase takes several weeks to a couple of months.

This phase is also used to make adjustments as needed and refine procedures.

Once evidence is available, we perform a Pre-Assessment. Any issues that surface are evaluated and remediated as needed until you are ready for the final CMMC Certification Assessment by a C3PAO (Level 2) or DoD officials (Level 3).
Alternatively, if you not required to become certified (Level 1 and part of Level 2) we can assist you with your annual self-assessment you will need to provide to the SPRS.

Certification Phase

~6-8 weeks

Certification Assessment

The Certification Assessment will be performed by a Certified 3rd Party Organization (C3POA) of your choice. If we were involved during the implementation phase we can help preparing by gathering and organizing the evidence and will be on site to defend the evidence and assist with any questions that might come up.

The entire assessment process will take 6-8 weeks and consists of 3 steps:

  1. Readiness Review: The C3PAO will request your documentation and review it.
  2. The Assessment: For this the C3PAO will come on-site for several days and will look at the individual controls and the evidence.
  3. Reporting Phase: ~2 weeks that it will take for the C3PAO to write the report.

The C3PAO will report it findings to the Cyber AB (formerly CMMC Accreditation Body) which will award you the certification.

If you have only CMMC Level 1 requirements or fall into the subset of Level 2 that does not involve information critical to national security, then this step does not apply to you.

CERTIFIED

Stay Compliant

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HOW WE CAN HELP

Ecuron is a CMMC Registered Provider Organization - CMMC-RPODue to our status as a CMMC Registered Practitioner Organization™ (CMMC-RPO), Ecuron can perform pre-assessment services which include CMMC gap analysis, CMMC implementation support, and CMMC pre-assessments. We do not conduct the final Certification Assessments.

Depending on your current cybersecurity status as well as the CMMC Level you are required to achieve, implementation of the new standard will take several months. Starting now by implementing the requirements and cyber security best practices will save you valuable time and will get you ahead of the curve and competition.

We offer CMMC Consulting Services to get you CMMC compliant in 4 Steps:

  1. CMMC Gap Analysis / CMMC Gap Assessment
    See where your organization stands and what it takes to achieve compliance
  2. CMMC Implementation Help
    Based on the results of the first phase we will help you to close existing gaps by implementing suitable controls and any missing requirements. This includes developing and writing the extensive documentation required.
  3. CMMC Pre-Assessment
    Think of it as a mock audit. We will verify that everything is in place, mature, and can be proven to an auditor. If we find issues we will help you fix them. Once we are confident that you are ready for the CMMC Assessment we will recommend to schedule the actual audit.
  4. CMMC Assessment Support
    We help you prepare for the certification audit, gather & organize evidence for a smooth assessment by the C3PAO. We will be at your side throughout the process.

If you would like to speak to our team to discuss your CMMC requirements and schedule a complimentary 15-30 min consultation, email us at cmmc@ecuron.com or give us a call.

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