# DoW Suspends CMMC Phase 2

The Department of War suspended CMMC Phase 2 on July 13, 2026, before its scheduled November 10 start date; no restart date has been announced, and the promised review has not been published. The suspension pauses the planned Phase 2 third-party assessment requirement, but it does not repeal existing cybersecurity clauses. Contractors handling covered information should continue to follow applicable contract and solicitation terms, including DFARS 252.204-7012 and relevant NIST SP 800-171 controls; Phase I self-assessment requirements may still apply.

- Contractors and subcontractors should verify the cybersecurity requirements in each solicitation and contract rather than assume that third-party assessments are either universally required or permanently withdrawn.
- Maintain current, accurate SPRS records and required affirmations, and keep compliance evidence ready for applicable award, option, or extension checks.
- Subcontractors should confirm obligations with their primes; solicitations may call for Level 1 or Level 2 self-assessments even while Phase 2 is paused.

**Jurisdictions:** federal
**Industries:** Defense & Military, Information Technology
**Topics:** Cybersecurity, Regulatory Compliance
**Published:** November 12, 2026

### Government Entities
- Department of War (DoW)
- Department of Defense (DoD)

### Vendors
- Shadowbear LLC ()

### Key Quotes
> The pause moved one deadline. It did not change the contract clauses most subcontractors have already signed.
> — Ian Garrett, Founder of Shadowbear

### Sources
- [CMMC Phase 2 was due Nov 10. It's suspended, not repealed.

DFARS 7012, NIST 800-171, 72-hour reporting and SPRS checks at award, option and extension all still apply.

A pause, not a stand-down.

https://t.co/CpDSrATnr7 https://t.co/l03axjIaWb](https://x.com/kghaynes/status/2119808270386798621) - twitter-regulatory
- [CMMC Phase 2 Remains Paused: What’s Next?](https://www.hunton.com/government-contracts-intelligence-briefing/cmmc-phase-2-remains-paused-whats-next) - Hunton Andrews Kurth LLP
- [Government Contracts Intelligence Briefing](https://www.hunton.com/government-contracts-intelligence-briefing/2026/11) - Hunton Andrews Kurth LLP