November 10, 2026, is the start of Phase 2 enforcement, when CMMC requirements evolve from self-attestation to independent, third-party validation.
This transition means CMMC compliance is no longer a project for your team to manage internally. Now, an OSC will need to get on the calendar with a C3PAO. As a result, demand for C3PAO assessments is increasing.
We've compiled a checklist of actions you can take now to prepare, but you will want to begin as soon as possible.
Phase 1: Minimize Your Footprint
One effective way to prepare is to reduce the amount of infrastructure that needs to be assessed.
- Identify your CUI: Clearly map where CUI is stored, processed, and transmitted.
- Consider Enterprise or Enclave: Determine if you can isolate CUI into a secure, dedicated enclave or if you need to include your entire enterprise. By limiting the scope to a specific environment, you drastically reduce the complexity of your audit and the cost of remediation.
- Purge unnecessary data: If you no longer need historical CUI, securely dispose of it. Less data equals less risk.
Phase 2: Evidence over Documentation
Assessors do not just want to see your policies; they want to see that those policies are working in real-time.
- Audit your logs: Ensure your systems are generating, storing, and reviewing logs. An assessor will ask, "Show me how you detected this event," not "Show me your incident response policy."
- Standardize configuration reports: Consolidate your hardware and software inventory. You must be able to prove that every device in scope is patched and configured according to NIST 800-171 standards.
- Create an "Evidence Locker": Organize your screenshots, configuration reports, and training records into a single, accessible repository. Being able to retrieve evidence on demand during an assessment is the hallmark of a high-functioning team.
Phase 3: The SPRS Reality Check
Your SPRS score is not just a data point, it is a legal representation of your security posture.
- Verify your score: Cross-reference your current SPRS score with your actual system configuration.
- Eliminate "wishful thinking": If a control is not fully implemented, do not claim it is. Inaccurate SPRS reporting is a primary target for oversight and can lead to severe False Claims Act (FCA) implications.
- Plan for POA&Ms: While some items may still be eligible for a Plan of Action and Milestones (POA&M), prioritize closing these gaps immediately to ensure you are as close to a perfect score as possible before an assessor arrives.
Phase 4: Proactive Scheduling
The "Audit Bottleneck" is a real threat to your business continuity.
- Assess your status: Honestly evaluate your internal timeline. Are you truly ready for an audit, or are you still building your foundation?
- Schedule with a C3PAO ASAP: Do not wait for a contract solicitation to arrive before looking for an assessor. Reach out to us today to understand scheduling and lead times.
- Secure your slot: Get on the calendar for late 2026 or early 2027. Locking in an assessment window early is the best way to ensure you don’t lose out on new contract opportunities due to a lack of certification.
Talk To An Expert Today
If you are uncertain where to begin, we're a quick phone call away. Schedule some time with one of our experts, and we can help you determine where you are in the journey and your next steps.
