10/10/2025
As the federal government shutdown reaches Day 10 with no resolution in sight, defense contractors are asking a critical question: Does this shutdown impact the November 10, 2025 CMMC implementation deadline?
The short answer: No. CMMC requirements remain on track.
Here’s what defense contractors need to understand about how the current government shutdown affects – or more accurately, doesn’t affect – your CMMC compliance obligations.
The November 10, 2025 Deadline Stands Firm
Despite the government shutdown that began October 1, 2025, the Cybersecurity Maturity Model Certification (CMMC) program will launch as scheduled on November 10, 2025. On that date, the Department of Defense will begin incorporating CMMC requirements into new defense solicitations and contracts.
The final rule has been published, and the implementation timeline is proceeding regardless of the current appropriations lapse.
Why CMMC Implementation Continues During the Shutdown
Several factors ensure that CMMC moves forward even while other government operations are curtailed:
1. The Regulatory Framework Is Already Established
The CMMC final rule was published in the Federal Register and became effective on December 16, 2024. The regulatory authority for contracting officers to include CMMC requirements in solicitations (DFARS clause 252.204-7021) is already in place. No additional legislative action is required.
2. DoD Contracting Activities Continue
The Department of Defense has funding to continue essential operations during the shutdown, including contracting activities. According to DoD shutdown guidance issued in September 2025, existing contracts are not terminated or paused unless new funding is needed, and contracting officers continue to perform their duties for essential defense operations.
3. C3PAOs Operate Independently
CMMC Third-Party Assessment Organizations (C3PAOs) are private sector entities authorized by the Cyber Accreditation Body (Cyber AB). They do not rely on government appropriations to conduct assessments. Your ability to schedule and complete CMMC assessments is unaffected by the shutdown.
4. The Cyber AB Functions as a Non-Profit
The Cyber AB, which accredits C3PAOs and manages the CMMC ecosystem, operates as an independent non-profit organization. Its operations continue normally during government shutdowns.
What May Be Temporarily Affected
While CMMC implementation proceeds, some peripheral activities may experience delays as the shutdown extends into its second week:
- Government Oversight Functions: Some DoD cybersecurity oversight and policy development activities may be reduced or delayed.
- New Solicitation Volume: The overall number of new contract solicitations may temporarily decrease as some DoD offices operate with reduced staff. However, essential defense contracting continues.
- DIBCAC Operations: The Defense Industrial Base Cybersecurity Assessment Center may have limited availability for questions or guidance during the shutdown.
- Training and Outreach: Government-sponsored CMMC training events and webinars may be postponed. The Defense Acquisition University (DAU) has suspended all classes and events that started on or after October 1.
- Military Pay at Risk: Active-duty military personnel (approximately 1.3 million service members) will miss their first paycheck on October 15, 2025 if the shutdown continues. This does not directly impact CMMC implementation timelines, but creates significant pressure for congressional action.
- Federal Worker Layoffs: The White House Office of Management and Budget announced on October 10 that “substantial” layoffs of federal workers have begun. This represents an escalation beyond typical shutdown furloughs and may affect some agency operations.
- Agency Response Times: Federal agencies are operating with limited staff, leading to delays in regulatory approvals and guidance responses.
- Congressional Recess: The Senate adjourned on October 9 and will not return until October 14, meaning no votes on funding legislation are possible until next week at the earliest. The shutdown is now expected to extend into Week 3.
However, none of these temporary impacts change your compliance obligations or the November 10 implementation date.
What Defense Contractors Should Do Right Now
The government shutdown should not slow your CMMC preparation. In fact, it reinforces the urgency of getting ready now.
For Companies Handling Federal Contract Information (FCI) – CMMC Level 1:
- Complete your self-assessment against the 17 CMMC Level 1 practices
- Document your security controls in your System Security Plan (SSP)
- Prepare to submit your annual self-assessment through the Supplier Performance Risk System (SPRS)
- Ensure you can obtain your CMMC Unique Identifier (UID) when required for contract bids
For Companies Handling Controlled Unclassified Information (CUI) – CMMC Level 2:
- Finalize your NIST SP 800-171 implementation across all 110 security requirements (and 320 assessment objectives!)
- Conduct internal readiness assessments to identify any remaining gaps
- Engage with a C3PAO to schedule your third-party assessment (lead times depend on the C3PAO but are now often 3-6 months or longer)
- Develop your Plan of Action & Milestones (POA&M) for any requirements you cannot yet meet
- Review your subcontractor relationships to ensure flowdown compliance
For All Defense Contractors:
- Monitor new solicitations closely starting November 10 for CMMC requirements
- Don’t wait for the shutdown to end to begin your compliance work
- Understand that False Claims Act implications remain in effect regardless of the shutdown—misrepresenting your cybersecurity posture carries serious legal and financial consequences
- Use this period productively to advance your CMMC preparation while solicitation volume may be temporarily reduced
- Plan for post-shutdown surge: When the shutdown ends, expect increased solicitation activity, compressed timelines, and greater demand for C3PAO assessments
The Four-Phase CMMC Rollout Timeline
Understanding the phased implementation helps you prioritize your preparation:
Phase 1 (November 10, 2025 – November 9, 2026): Selective application of CMMC requirements in new solicitations. DoD will begin incorporating CMMC clauses, but not all contracts will require certification immediately.
Phase 2 (November 10, 2026 – November 9, 2027): Increased application across more contract types and dollar thresholds.
Phase 3 (November 10, 2027 – November 9, 2028): Broader enforcement with more contracts requiring CMMC certification.
Phase 4 (November 10, 2028 and beyond): Full implementation across all applicable DoD contracts, except those exclusively for commercial off-the-shelf (COTS) products.
For more details see our post CMMC: Phased Rollout Timeline .
Even though implementation is phased, you cannot predict which solicitations will require CMMC. or if a self-affirmation or C3PAO assessment is required. Waiting until your specific contract requires certification puts you at serious competitive disadvantage.
Why This Shutdown Is Different for Cybersecurity
In past government shutdowns, many regulatory initiatives were delayed or suspended. CMMC is different for several important reasons:
- Regulatory Authority Already Granted: Unlike programs requiring new legislation or funding, CMMC operates under existing regulatory authority that remains valid during shutdowns.
- Private Sector Assessment Model: The use of independent C3PAOs means the assessment infrastructure doesn’t depend on government employees or appropriations.
- National Security Imperative: Cybersecurity threats to the defense industrial base continue regardless of appropriations status. The DoD views CMMC as essential to protecting sensitive defense information.
What Happens After the Shutdown Ends
When appropriations are restored and government operations return to normal, expect:
- Increased solicitation activity as delayed contracts move forward
- More CMMC requirements appearing in solicitations as contracting officers catch up on backlogged work
- Compressed timelines for proposal submissions as agencies work to obligate funds before the fiscal year ends
- Greater scrutiny of cybersecurity compliance as the DoD emphasizes supply chain security
- Potential surge in C3PAO demand as contractors rush to complete assessments
- Restoration of military pay and federal worker salaries, with back pay typically provided for all affected employees
Contractors who used the shutdown period to advance their CMMC preparation will be positioned to respond quickly when opportunities arise.
TLDR
The current government shutdown does not impact:
- The November 10, 2025 CMMC effective date
- Your compliance obligations under DFARS 252.204-7012
- The phased rollout timeline
- C3PAO assessment operations
- Your ability to prepare for CMMC certification
The shutdown may temporarily affect:
- Government response times for questions or guidance
- The volume of new solicitations
- DoD-sponsored training and outreach events
- Agency staffing and administrative functions (with substantial layoffs now underway)
- Military pay (first missed paycheck on October 15)
For defense contractors, the message is clear: Continue your CMMC preparation without delay. The November 10 deadline is firm, the requirements are established, and the assessment infrastructure is operational.
The government shutdown is a temporary disruption to appropriations. CMMC is a permanent change to how the Department of Defense protects sensitive information across its supply chain.
As the shutdown reaches Day 10 with Congress adjourned until October 14 and no clear path to resolution, the contractors who maintain momentum on their compliance efforts will be best positioned for success when government operations normalize.
Need Help Preparing for CMMC?
Whether the government is open or in shutdown, cybersecurity threats don’t take a break—and neither should your compliance preparation.
Ecuron specializes in helping defense contractors navigate CMMC requirements, from gap assessments to full implementation and maintenance support. As a CMMC Registered Practitioner Organization (RPO), we understand both the technical requirements and the practical realities of achieving certification.
Contact us today to discuss your CMMC readiness:
- Phone: +1-713-646-5044
- Email: cmmc@ecuron.com
Don’t let the government shutdown become an excuse for delay. Your competitors are preparing—make sure you are too.