CMMC Phase II Suspended: What Defense Contractors Must Do About Active Solicitations Now - Crowell & Moring LLP
CMMC Phase II has been suspended, but active solicitations still require compliance with existing cybersecurity requirements. Defense contractors must continue to meet DFARS 252.204-7012 and NIST SP 800-171 controls.
Aforeworn detected this change in the Government Contracting (SAM/FAR) space on July 22, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Defense contractors with active solicitations or contracts containing DFARS 252.204-7012 clause should confirm how it applies to their specific situation before acting. There is a time constraint attached: Immediately for active solicitations; ongoing for contract performance. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Government Contracting (SAM/FAR) continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
CMMC Phase II rulemaking suspended, but existing cybersecurity requirements remain in effect for active solicitations
Who it affects
Defense contractors with active solicitations or contracts containing DFARS 252.204-7012 clause
What you must do
Continue to comply with DFARS 252.204-7012 and NIST SP 800-171; do not assume suspension relaxes obligations
Deadline
Immediately for active solicitations; ongoing for contract performance
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