Phased Implementation of CMMC Level Requirements
Starting November 10, 2025, DLA will begin a phased implementation of CMMC requirements in accordance with DFARS 204.75 .
How to Prepare: To help our industry partners prepare, DLA has identified which National Item Identification Numbers (NIINs) will require either:
- Level 2: Requiring a self-assessment or a third-party (C3PAO) certification.
- Level 3: In rare cases, requiring a Government-led (DIBCAC) certification.
What to Expect
Defense contractors who process, store, transmit, or handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) must demonstrate compliance with CMMC requirements before contract award. These requirements will appear in DLA solicitations and contracts through Clauses, Procurement Notes, and Standard Text Objects (STOs). This does not apply to procurements of purely Commercial-Off-The-Shelf (COTS) items.
While most contracts will follow a three-year phased approach, please be aware that any DLA contract issued after November 10, 2025, may include CMMC requirements. See solicitations and contracts for additional information.
See the below for an overview of phased implementation details.
