The Department of Defense (DoD) has moved decisively to strengthen cybersecurity requirements across the Defense Industrial Base (DIB). The two critical regulations at the heart of this change are 32 CFR Part 170 and 48 CFR.
32 CFR Part 170 (CMMC Program Rule) established the framework of the Cybersecurity Maturity Model Certification (CMMC), including the certification levels, assessment requirements, and program structure. It took effect in October 2024.
The enforcement mechanism is 48 CFR (Federal Acquisition Regulations, specifically DFARS parts). By embedding CMMC requirements directly into contracts, 48 CFR makes CMMC mandatory for contractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI).
On September 10, 2025, the rule will be published into the Federal Register, and on November 10, 2025, it will become final and enforceable.
Once the rule go live, CMMC requirements will immediately begin appearing in contracts and the Phase 1 rollout will begin. This timeline means defense contractors have little time to delay: CMMC compliance is no longer optional. It is a contract award requirement.
Most organizations take 9–12 months to achieve full CMMC Level 2 readiness. Waiting until contracts begin requiring certification could disqualify companies from new opportunities. Waivers are rare and cannot be relied upon. The urgency is real.
A Deeper Dive into Title 48 CFR
The Code of Federal Regulations, Title 48 (48 CFR), commonly known as the Federal Acquisition Regulation (FAR) and its agency supplements, establishes the rules that govern how the U.S. government acquires goods and services.
For organizations in the Defense Industrial Base (DIB), specific clauses within 48 CFR require contractors and subcontractors to follow strict cybersecurity and compliance standards in order to protect sensitive government information.
These rules are not guidelines; they are legally binding requirements written directly into federal contracts, and reshape how DIB organizations approach cybersecurity and compliance.
For contractors and subcontractors working with the Department of Defense (DoD), DFARS clause 252.204-7021 directly ties eligibility for contracts to compliance with the Cybersecurity Maturity Model Certification (CMMC) framework.
In short, if your organization is not prepared to demonstrate compliance with 48 CFR requirements, you risk losing valuable government contracts.
Why This Matters to Defense Contractors
- CMMC will be phased in: self-assessments may be acceptable initially, but third-party C3PAO assessments will become the standard.
- Contracting officers will now require proof: with 48 CFR in effect, CMMC certification will be a prerequisite for contract award.
- Non-compliance carries risk: contract loss, withheld payments, and False Claims Act liability.
Why 48 CFR and CMMC Go Hand-in-Hand
The CFR clauses require organizations to safeguard Controlled Unclassified Information (CUI), meet National Institute of Standards and Technology (NIST) standards, and provide verified proof of compliance. That proof is delivered through CMMC certification. Here is the flow:
- 48 CFR enforces the rules: It’s the legal requirement written into contracts.
- CMMC provides the standard: It defines how cybersecurity and compliance must be demonstrated.
- C3PAOs deliver the validation: Only an accredited CMMC Third Party Assessment Organization (C3PAO) can conduct assessments that lead to certification.
How ControlCase Can Help
As both an authorized C3PAO (Certified Third-Party Assessment Organization) and an RPO (Registered Provider Organization), ControlCase offers defense contractors navigating CMMC a unique advantage.
As a C3PAO, we can conduct your official CMMC assessments or mock assessment when you are ready.
As an RPO, we can provide readiness services—including gap assessments, remediation guidance, documentation support, POA&M development, and evidence validation—without conflict of interest.
This dual capability allows ControlCase to support you with either readiness or certification, ensuring your organization can confidently meet the requirements of CMMC.
Final Thoughts
Defense contractors cannot afford to wait. The publication of the final 48 CFR rule cements CMMC into acquisition law, and deadlines are fast approaching. Companies that begin their compliance journey now will be positioned to win contracts in 2025 and beyond.
As a best practice, talk to your primes or contracts officers and work with ControlCase to determine the next best steps for your company or your clients.
ControlCase is ready to partner with you every step of the way—from preparation to official certification.
Learn more about ControlCase’s C3PAO assessments by downloading our CMMC Cheat Sheet here.
Understand your current readiness for CMMC by taking our free Self-Assessment here.