The unbuilt 800-171 floor
On July 13, 2026 the Department suspended CMMC Phase II, the mandatory third-party certification originally scheduled for November 10, 2026, and opened a reform review. Phase I did not move: a Level 2 self-assessment every three years against the 110 NIST SP 800-171 Rev 2 requirements, with annual affirmation into SPRS. DFARS 252.204-7012 binds today, and per CyberSheath's 2025 State of the DIB report only 1 percent of contractors feel fully prepared.
The exposure
The certificate paused. The obligation did not. Your prime cannot award you covered work without a current assessment.
The first move
Give each of the 110 controls an owner, then close the gaps before the next annual affirmation puts your name on them.

