The landscape of cybersecurity compliance in the defense supply chain is shifting. For years, the Department of Defense (now Department of War) has asked its supply chain to safeguard sensitive data, and the Title 48 ruling has caused significant changes to enforcement.
What Is the Title 48 Ruling?
On September 10, 2025, the Final Rule was published by the US Federal Register updating the Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7021, and adding a new clause (252.204-7025). These changes will integrate Cybersecurity Maturity Model Certification (CMMC)-level requirements into contract and solicitation languages as of November 10, 2025 for all government contracts made with the DoD/DoW. As a result, any company receiving a DoD/DoW contract will require a specific CMMC level to qualify as a contractor.
Sub-contractors who handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) are also in scope of this ruling, which mandates that any business under a primary contractor with the DoD/DoW are also required to achieve the necessary CMMC status.
Impact on Defense Industrial Base Suppliers
Beginning November 2025, all primary and sub-contractors of the DoD/DoW must be able to prove CMMC status. Businesses that do not meet required CMMC levels may be ineligible to bid or receive an award.
As a result, this also means prime contractors of the DoD/DoW will begin asking their subcontractors for evidence of CMMC compliance to ensure they are able to bid on new, and renew existing, DoW contracts. Any prime contractor whose subcontractors cannot provide CMMC certification may re-source.
Implementation & Certification Timelines
Depending on the CMMC level required for the materials being provided to the DoD/DoW, the journey for compliance can be lengthy, particularly if you do not already have a process established for your supply chain due diligence. For example, if you only receive FCI, you will only need a Level 1 self assessment. Once CUI is involved, Level 2 with a Certified Third-Party Assessment Organization (C3PAO) will be a requirement. While Level 1 certification is done as a self assessment and attestation, which may be relatively quick, preparing and implementing a Level 2 requires significant time and work. For most companies, this can take nine to 12 months depending on how many controls are already established and documented.
Although not all primary or subcontractors will require Level 2 CMMC certification, being able to prove certification upfront, rather than having to gain the certification upon contracts being awarded, provides a competitive advantage for businesses whose parts or products are part of the DoD/DoW supply chain.
Final Thoughts
The Title 48 rule for CMMC is the beginning of a new world in DoD/DoW contracting. Once a nice to have, CMMC is now a firm contractual requirement for contracts. For businesses that supply the DoD/DoW, directly or indirectly, who handle FCI or CUI, CMMC is essential to doing business. As enforcement ramps up, businesses that use the ramp up time to gain CMMC certification will see clear competitive benefits in preserving access to DoD/DoW opportunities.
Stay ahead of peers by standing up a CMMC program. The AI-native Assent Sustainability Platform standardizes outcomes for reduced risk, a resilient supply chain, and uninterrupted market access.
Book a demo with an Assent expert today to learn how we can help you meet your CMMC requirements and maintain access to DoD contracts.
