CMMC Final Rule Clears Regulatory Review:
What are the Implications?

August 29th 2025

We are close, very close. The wait is almost over. After years of anticipation, the 48 CFR final rule has officially cleared regulatory review on August 25th, marking a pivotal moment for defense contractors across the nation.

What Happens Next?

The review by OIRA was finalized well under the 90 day limit. Not much is left before the rule takes effect:

Within the next week: The rule will be published in the Federal Register, officially marking the beginning of the end of the preparation phase.

1-60 days after publication: The effective date kicks in, launching Phase 1 of the CMMC phased rollout. As mentioned in our previous blog post, the 48 CFR is no major rule and thereby no 60 day delay is required.

From the effective date forward: Every new DoD solicitation and contract will include CMMC requirements. No exceptions.

Not Just Self-Assessments

Here’s what many contractors are getting wrong: this isn’t just about self-assessments.

Contrary to popular belief circulating in industry forums, new contracts can easily require CMMC Level 2 certification right from the start when the contract includes CUI of the Defense Category — not just the self-assessment that many contractors have been banking on as a “soft landing.”

If you’ve been putting off your CMMC preparation thinking you’ll have more time to ease into compliance, it’s time to recalibrate your timeline.

No Surprises in the Final Rule

Don’t expect dramatic changes from what we’ve already seen. This final rule simply implements the policy that’s been codified at 32 CFR 170 since December 2024.

What it does accomplish:

• Updates instructions to contracting officers
• Revises the text of DFARS 252.204-7021
• Implements the overall CMMC program policy we’ve been preparing for

Think of it as the operational manual for a policy framework that’s already been established.

What This Means for Your Business

The preparation window is closing. Once that effective date hits, every new opportunity in the defense sector will come with CMMC strings attached.

For contractors who haven’t started their CMMC journey:

• Gap assessments become urgent, not optional
• Implementation timelines need to be compressed
• Certification planning should begin immediately

For those already in progress:

• Stay the course—your early preparation is about to pay dividends
• Ensure your implementation timeline aligns with your contract renewal dates
• Consider accelerating certification if you’re pursuing new opportunities

The CMMC program is no longer a future consideration—it’s an immediate business reality. Defense contractors who treat this as just another compliance checkbox are setting themselves up for lost opportunities and competitive disadvantage.

The time for preparation is now.

If you need help navigating your CMMC compliance journey: Our team at Ecuron specializes in helping defense contractors implementing the requirements of NIST SP 800-171 and prepare you for a CMMC certification efficiently and effectively. Contact us at cmmc@ecuron.com for a no string attached 30 minute consultation to discuss your specific situation and requirements.