With the activation of CMMC Phase 1 on November 10, 2025, contractors meeting Level 1 Maturity (and, in some cases, Level 2) can provide self-assessment documentation in lieu of undergoing an audit with a C3PAO. This means that every cybersecurity claim a defense contractor makes now carries the same legal weight as a cost or performance claim. 

But what does this mean for contractors in the DIB? In many cases, while it opens up plenty of opportunities to streamline compliance through self-reporting, it also opens up legal liability if that reporting isn’t accurate. 

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As the CMMC program evolves in 2026, following the solidification of the final rule and the timelines for required certification, the Cyber AB wrestles with the need to streamline adoption across contractors while maintaining strict rigor in compliance and audits. That’s where waivers come in. 

Now, across the DIB, executives have to decide whether these waivers are legitimate from a strategic perspective or something so niche and unreliable that they don’t expect to receive one. Understanding this balance is critical for organizations as they shape their long-term compliance and growth.

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With the final rule for CMMC now in place and the phased rollout underway, organizations that handle FCI or CUI are entering a period where preparation has moved from the theoretical to a practical necessity.

This article breaks down what preparation looks like in 2026: the decisions organizations are making, the challenges they face, the timelines that matter, and the strategic opportunities available for those who treat CMMC as more than a compliance checkbox.

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