What the Final 48 CFR Rule Means for Defense Contractors

For contractors in the Defense Industrial Base (DIB), the clock has officially started ticking on CMMC enforcement. On July 22, 2025, the Department of Defense (DoD) submitted the final 48 CFR rule to the Office of Information and Regulatory Affairs (OIRA). It’s a decisive step that paves the way for Cybersecurity Maturity Model Certification (CMMC) requirements to begin showing up in DoD contracts as soon as this fall. 

While the cybersecurity community has been watching for this rule for years, this is no longer a theoretical milestone. It’s a regulatory trigger, and it means that real compliance expectations are about to hit real contract solicitations.

At Sera Brynn, we’ve been guiding defense contractors and suppliers through the complexities of CMMC readiness since the program was first introduced. We’ve seen how easy it is for otherwise capable businesses to delay preparations or misread the intent of these rules. With the 48 CFR update now in motion, the margin for error has vanished.

In this article, we’ll break down what the 48 CFR rule means, when it goes into effect, and how your organization should be preparing, right now. 

What is the 48 CFR Rule, and Why Does It Matter?

CMMC is governed by two key regulatory structures:

• 32 CFR Part 170 – Defines the CMMC program: levels, requirements, waivers, and assessments.
• 48 CFR (Parts 204, 212, 217, 252) – Implements CMMC into DoD acquisition policy, enabling CMMC requirements to be embedded into contracts.

While 32 CFR Part 170 has been in effect since December 2024, it’s the 48 CFR rule that authorizes Contracting Officers to enforce CMMC through acquisition clauses—specifically DFARS 252.204-7021.

Until now, CMMC could exist as guidance. With 48 CFR, it becomes contract law.

This distinction matters. Without 48 CFR in place, contracting officers couldn’t formally require CMMC levels in Requests for Proposals (RFPs) or contracts. With it, they can—and will. 

Timeline: When Will CMMC Start Appearing in Contracts?

As of now, here’s how the timeline is shaping up:

• July 22, 2025 – DoD sends the final 48 CFR rule to OIRA for review.
• OIRA Review Period – Typically takes 90 days but can extend up to 120.
• Post-Review Publication – Once cleared, the rule moves to the Federal Register for final publication (typically within 1–3 weeks).
• Effective Date – The rule becomes enforceable immediately upon publication.

Most Likely Scneario:

CMMC language begins appearing in contracts as early as October 2025. 

Conservative Scenario:

With review delays, it could be early 2026, but by then, your certification should already be in place.

Whether you’re an optimistic planner or a cautious one, the takeaway is clear: the window is closing fast. And defense contractors that haven’t begun serious CMMC readiness efforts are already behind.

What's Actually Changing?

Importantly, this final rule doesn’t rewrite the CMMC requirements themselves, those were codified in 32 CFR. Instead, the 48 CFR update operationalizes the program.

Here’s what’s being added:

• DFARS Clause 252.204-7021: This clause allows contracting officers to insert CMMC requirements directly into solicitations.
• Enforcement Authority: Once this clause appears, bidders must show evidence of the required CMMC level at the time of contract award.
• Rollout Timeline: Initiates the formal four-phase rollout of CMMC across the DIB, beginning with prioritized contracts and expanding from there.

So if you were waiting for a “go” signal, this is it. CMMC isn’t aspirational anymore. It’s actionable.

What Defense Contractors Need to Do Now

The biggest mistake we see from organizations is assuming that they still have time. But implementing NIST SP 800-171 and preparing for a C3PAO assessment is not a quick process. For most companies, the journey from gap analysis to certification takes 9–12 months.

That means, if you:

• Handle Controlled Unclassified Information (CUI)
• Work as a prime or subcontractor on DoD contracts
• Plan to compete for federal contracts in 2026 or earlier

 …then you should already be in the assessment phase.

Consider the Timeline:

• Solicitations can drop with little warning.
• Contract awards often happen 30–60 days later.
• That leaves no time to scramble for certification.

Even if your team is highly capable, the logistics, scheduling an authorized CMMC Third Party Assessment Organization (C3PAO), resolving findings, and compiling evidence, don’t happen overnight.

The message is simple: Start now, or risk being disqualified later.

Misconceptions About Waivers and Grace Periods

Another common pitfall? Believing you can get a waiver. 

CMMC waivers are not granted ad hoc. They are:

• Pre-approved at the acquisition level—not for individual subcontractors or late bidders.
• Rare—waivers are used sparingly and only for mission-critical situations.
• Not a safety net—they will not save you from poor preparation.

Contracting Officers have discretion, and many will require proof of certification before contract award. Betting on flexibility is a gamble you can’t afford.

Need Help Getting Your Company CMMC Ready?

CMMC is no longer a future requirement. With the final 48 CFR rule now under regulatory review, enforcement is on track for late 2025. That means DoD contract eligibility will soon hinge on whether your organization has achieved CMMC compliance.

If you haven’t started your compliance journey, the time for planning is over. It’s time to act.

At Sera Brynn, we’ve helped hundreds of defense contractors and suppliers across the country prepare for CMMC. We can start with conducting realistic gap assessments and guiding you through remediation, documentation, and readiness for a third-party assessment.

We’re a CMMC-AB Registered Provider Organization (RPO), and our team brings decades of combined experience in NIST-based cybersecurity frameworks, regulatory compliance, and DoD acquisition processes.

Let us help you build a compliance program that isn’t just audit-ready, but resilient and sustainable. Schedule a no-cost readiness consultation with our experts today.