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CMMC Hit Pause, the FAR Council Hit Play
DoD paused CMMC Phase 2 pending a 60-day review while a proposed FAR Council rule would extend NIST 800-171 Rev 3 to all federal contractors.
The Department of Defense suspended CMMC Phase 2 third-party certification requirements, but Phase 1 self-assessments under DFARS 252.204-7021 remain in force since November 2025, and prime contractors are still directing suppliers to proceed. A CMMC Reform Task Force must report recommendations to the DoD CIO within 60 days, likely by September or October 2026. Separately, the FAR Council's proposed CUI rule from June 23 would apply NIST 800-171 Revision 3, 72-hour incident reporting, and flowdown obligations to all FAR-based federal contracts, not just the defense industrial base. False Claims Act exposure grows as DIBCAC assessment teams now cooperate directly with the DOJ.
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