Phased Implementation of CMMC Requirements at DLA
DLA will implement Cybersecurity Maturity Model Certification (CMMC) 2.0 pursuant to DFARS 204.75 using a phased approach beginning on the effective date of November 10, 2025. As part of this rollout, DLA may gradually introduce requirements, in the form of DLA Procurement Notes and Standard Text Objects (STOs), aligned with the appropriate CMMC levels.
To support early visibility for industry partners, DLA has identified which NIINs will correspond to Level 2 (self-assessment or C3PAO certification) and, in rare cases, Level 3 (DIBCAC certification). While final DLA procurement policy is still in development, more guidance will be provided near the DFARS effective date.
To increase the cybersecurity posture of the Defense Industrial Base and better protect sensitive unclassified information, all defense contractors and subcontractors must demonstrate compliance with applicable security requirements—through self-assessment or independent assessment—prior to contract award, excluding Commercial-Off-The-Shelf procurements.
CMMC requirements may appear in any contract after November 10, 2025, if included by the requiring activity. However, for most DLA contracts, DLA will follow the phased approach outlined below:
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Phase 1 - Initial Implementation
- Begins at 48 CFR Rule Effective Date, 10 Nov 2025
- Where applicable, solicitations will require Level 1 (Federal Contract Information (FCI)) or 2 Self-Assessment (Controlled Unclassified Information (CUI))

Phase 2
- Begins 12 months after Phase 1 start, 10 Nov 2026
- Where applicable, solicitations will require Level 2 Certification (CUI) Certified Third Party Assessment Organization (C3PAO)

Phase 3
- Begins 24 months after Phase 1 start, 10 Nov 2027
- Where applicable solicitations will require Level 3 Certification (CUI)

Phase 4 - Full Implementation
- Begins 36 months after Phase 1 start
- Solicitations and contracts will include applicable CMMC Level requirements as a condition of contract award
- At full implementation (Nov 2028), DLA will accept CMMC Final, and CMMC Conditional will be accepted only in limited case-by-case exceptions (DLAD 4.7503)
- Fully certified
- Valid for 180 days, requires manual review, tracking, extra justification, and approval