The unbuilt 800-171 floor
On July 13, 2026 the Department suspended CMMC Phase II, the mandatory third-party certification step 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 unless your assessment is current, and whatever the review returns, the shop that built the floor is ready and the one counting down to a date is not.
The first move
Map the 110 controls to who owns each one, then close the gaps before the next annual affirmation puts your name on them.
