Updated September 4th, 2026 to reflect the September 3rd class deviation, the status of the CMMC Reform Task Force, and recent enforcement actions. On July 13, the Department of War suspended CMMC Phase 2, the third-party (C3PAO) certification requirements that were set to become a condition of award on November 10, 2026. On September 3, that pause was written into acquisition policy through a formal class deviation, making it more durable than a memo alone. That has created
