CMMC Phase 2 Arrives in 2026: How to Prepare

Michael Peters

2 days ago

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.

The Shift from Planning to Execution in 2026

The shift to CMMC began with Phase 1, which landed in late 2025. This phase established mandatory self-assessments in the industrial base. Phase 2, starting November 10, 2026, is the next evolution of this process, in which third-party assessments for Level 2 become a requirement across an increasing number of contracts.

2026 marks the threshold at which organizations can no longer rely on partial NIST 800-171 implementation, incomplete documentation, or optimistic self-assessments.

Phase 2 introduces a significant shift:

Third-party Level 2 assessments become the standard for many solicitations that handle CUI.
Self-attestation alone is no longer sufficient for most environments handling sensitive data. While these are still subject to approval in some areas, the actual contexts where sensitive data is dealt with will typically forego self-attestation.
Documentation quality and continuous compliance become central to staying eligible for contract awards. This means a regular, ongoing audit and maintenance of records and reporting.
Supply-chain expectations are tightening, requiring stronger coordination with partners and vendors that handle FCI or CUI.

What Are Organizations Doing Now?

By this point, almost every organization that handles CUI has started taking visible steps toward certification. But 2026 introduces a practical reality that there’s not much runway left to meet requirements.

The following activities are happening across the ecosystem as organizations wrestle with the operational meaning of CMMC Phase 2.

Preparing for C3PAO Scrutiny

Organizations that haven’t already engaged a C3PAO are actively seeking one. But preparation goes much deeper than booking an assessment. You don’t want to wait for the C3PAO to show up and simply remediate all your security issues.

Readiness in 2026 includes:

Conducting a pre-assessment or rehearsal audit.
Verifying that each control has supporting evidence.
Ensuring policies exist, are approved, and match operational reality.
Tightening documentation around exceptions and risk decisions.
Eliminating “to-be-implemented” placeholders in the SSP.

The SSP is something an auditor can read and find every required detail. In years past, organizations treated documentation as a compliance artifact. In 2026, it becomes a survival tool.

Strengthening Continuous Monitoring Programs

One of the biggest changes introduced by the final rule is the shift toward always-on compliance. It’s no longer acceptable to get everything in shape right before an audit and then relax afterward. Organizations now need to operate as if an assessment could happen at any time.

Throughout 2026, teams are focusing heavily on tightening their monitoring programs and making them more sustainable:

Rolling out automated scanning tools to catch configuration drift before it spreads across systems. This helps teams spot unauthorized changes quickly and keeps baselines stable without relying on manual checks.
Deploying continuous control monitoring solutions that provide real-time insights into whether key security controls are actually operating as documented—not just configured once and forgotten.
Updating change-control workflows so they genuinely reflect how CUI systems work, with tighter approvals, clearer documentation, and careful tracking of updates that could affect compliance.
Revisiting POA&Ms to create realistic remediation timelines, ensuring that open items don’t linger indefinitely and that required milestones can be shown to an assessor if needed.

Revising System Boundaries and Architecture

Many environments have grown over time, accumulating systems that don’t truly need to touch CUI but still end up inside the compliance boundary. By 2026, teams are working to simplify and shrink that footprint to make their environments easier to manage, secure, and ultimately certify.

This reevaluation of system boundaries and architecture often includes:

Segmenting networks so CUI lives in a smaller, well-defined set of systems, making it easier to protect, monitor, and demonstrate compliance for the portions of the environment that matter most.
Replatforming sensitive workloads into cloud services with FedRAMP authorization, taking advantage of inherited controls and more consistent security baselines while reducing the burden on internal teams.
Eliminating unmanaged endpoints and reducing local storage, especially in areas where CUI shouldn’t reside in the first place. This cuts down on risk and reduces the number of devices that fall within the audit scope.
Applying Zero Trust practices around identity and access, ensuring that only the right users, from the right devices, at the right time, can access CUI systems, backed by strong authentication, continuous verification, and least-privilege design.

Addressing the Supply-Chain Pressure

CMMC’s Phase 2 requirements are accelerating the shift to supply chain-focused security and a more resilient ecosystem around sensitive data. The goal isn’t just to satisfy auditors—it’s to make sure partners and suppliers don’t introduce unnecessary risk.

With that in mind, organizations are taking several concrete steps to mature their supply-chain posture:

Requesting verifiable assurance from partners that touch FCI or CUI, not just accepting a signed PDF or a vague statement of intent. Teams are requesting documented practices, scorecards, or assessments that demonstrate suppliers are genuinely moving toward compliance.
Updating subcontractor agreements to embed CMMC expectations into the relationship, including explicit requirements for control implementation, reporting obligations, and timelines for achieving compliance milestones.
Phasing out vendors who cannot (or will not) meet minimum security requirements, especially those handling any part of the CUI environment. Instead of waiting for risk to materialize, teams are proactively replacing high-risk partners with more capable ones.
Offering templates, clear requirements, and structured timelines to help suppliers understand what’s expected, reducing confusion and enabling partners to build their compliance roadmaps in a way that aligns with upcoming contract phases.

CMMC Certification Timelines in 2026

Another reason organizations are accelerating preparation is the sheer length of the certification process. By 2026, the timeline looks roughly like this:

Remediation: 3–12 months, depending on control maturity
Internal validation and evidence collection: 1–3 months
Scheduling with a C3PAO: 2–6 months wait time (or more during peak demand)
Formal assessment: 1–2 weeks
Response to findings / POA&M adjustments: 30–90 days

That means even highly organized teams can expect at least 6–12 months to achieve certification from the moment they begin tightening controls. Waiting until late 2026 is simply not viable.

The Phase 2 Audit Experience: What Auditors Will Look for in 2026

Auditors in 2026 will expect organizations to show:

Clear SSP Documentation: The SSP must describe every system, boundary, control, customization, inherited service, and technology used to secure CUI. If something is not documented correctly, it doesn’t exist.
Evidence That Proves Implementation: Auditors will look for screenshots, tickets, logs, system certifications, training records, change control evidence, architecture documentation, etc.
Operational Consistency: Controls must be implemented consistently every time. For example, MFA must be enforced for every privileged account, log retention must meet the timeline claimed in the SSP, patching schedules must match stated policies, and incident response plans must match the environment.

The Strategic Advantage of Early Certification

When it comes to certification, earlier is always better. Getting ahead of CMMC positions your organization much more competitively than not, and saves your company significantly on overhead related to poorly-configured systems and missed obligations.

Some of the key advantages of early certification include:

When RFPs begin requiring third-party certification, those already holding a valid assessment can immediately step into proposal development, while others are still navigating remediation plans, scheduling bottlenecks, and internal system corrections.
As primes and larger integrators evaluate their supply chains, partners with compliance maturity become far more competitive. Being ready early signals reliability, risk awareness, and operational discipline… qualities that larger partners increasingly look for as they tighten oversight of subcontractors handling FCI or CUI.
Organizations that complete certification early benefit from these improvements sooner, resulting in predictable maintenance cycles, fewer ad-hoc fixes, and a more stable security architecture. Over time, these efficiencies reduce both cost and operational drag, giving early adopters a smoother path into continuous compliance.
When organizations prepare under less urgent conditions, they make better decisions about budgets and tools. Those who wait until late 2026 or 2027 will likely face congested assessor availability, higher consulting costs, and rushed remediation projects that burn resources and increase errors.

CMMC Is Becoming Real in 2026. Get Ahead with Lazarus Alliance

The CMMC rollout plan gives organizations a long runway, but the runway ends much sooner than it appears. Phase 2 in 2026 introduces the first major enforcement milestone, and every organization that handles CUI must be ready for third-party assessment.

To learn more about how Lazarus Alliance can help, contact us.

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