Starting November 10, 2025, new DoW solicitations and contracts can include CMMC requirements. Many small businesses will need either a quick self‑assessment (what folks often call “self‑attestation”) or a third‑party certification to stay eligible. Here’s the plain‑English version and how CyMyCloud makes it easier.
What changes when?
- Phase 1 (starts Nov 10, 2025): many contracts will require a current Level 1 or Level 2 self‑assessment posted in SPRS. Some may already require third‑party certification at Level 2; check your solicitation.
- Phased rollout: DoW will phase requirements in over ~3 years; by the end, CMMC appears broadly across DoW contracts. Some programs can add it earlier.
- Level 1 (FCI only): annual self‑assessment + annual affirmation in SPRS.
- Level 2 (CUI): either self‑assessment or third‑party (C3PAO) certification every 3 years, your solicitation will say which. Annual affirmation still required.
- Level 3: a small slice of programs with higher risk; assessed by DoW.
- Your current CMMC status and/or SPRS score must be present and current when they check.
- Level 2 may require a valid C3PAO certificate, depending on the RFP.
- Know your level. If you only touch FCI, plan for Level 1. If you handle CUI, plan for Level 2 and verify whether your RFP demands a C3PAO certification.
- Do a quick NIST 800‑171 gap check. You need a System Security Plan (SSP), a POA&M for fixes, and a calculated SPRS score (score can be negative; honesty matters).
- Post to SPRS + set reminders. Submit your score, and set a recurring reminder for the annual affirmation (and certification cycle if applicable).
Common snags (so you can avoid them)
Asset inventory gaps • MFA not enforced everywhere • Admin accounts shared • Logs not retained/monitored • No SSP/POA&M artifacts • Unclear CUI boundary • Third‑party/vendor risk unmanaged • Backups not tested
How CyMyCloud makes CMMC simpler
- Turnkey, NIST 800‑171–aligned environment: secure workspace for FCI (Soon CUI) with access control, MFA, encryption, logging, and backup options.
- Ready‑to‑use paperwork: SSP & POA&M templates mapped to controls; evidence collection built into daily operations.
- SPRS‑ready reporting: roll‑up of implemented controls and gaps to speed self‑assessments.
- “C3PAO‑friendly” posture: if your RFP requires third‑party certification, CyMyCloud helps you define the boundary, gather artifacts, and walk into assessments prepared.
- Small‑team friendly: our team handles the heavy lift so you can stay billable.
FAQ (quick hits)
Is Level 1 just paperwork? No, there are 15 required safeguards, plus an annual self‑assessment and affirmation in SPRS.
For Level 2, do I always need a C3PAO? Not always. Some contracts allow self‑assessment; others require a third‑party certification; read the solicitation.
My score isn’t perfect. Am I doomed? Nope. Scores can be negative. Focus on an honest SSP, a real POA&M, and closing gaps. (POA&Ms are allowed for Level 2, and you’ll need to close them on a deadline.)
If you want help figuring out “self‑assessment vs certification” in your situation, just reply to this newsletter and say “CMMC”. We’ll respond same day.
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CyberMyte
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Yvonne Rivera CEO
- October 15, 2025
- (855) 665-4308
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