How to finish CMMC certification on schedule

This article is part 3 of a series on CMMC Certification. Learn more by reading What You Need to Know About CMMC and CMMC Myths.

October 2025

• Complete gap assessment
• Calculate baseline SPRS score
• Identify which level you need (probably Level 2)
• Get 3 C3PAO quotes and BOOK YOUR SLOT for summer 2026

November 2025

• Create implementation roadmap
• Assign internal CMMC lead
• Start weekly security awareness training
• Implement MFA on email and remote access
• Review cyber insurance coverage

December 2025

Finalize 2026 budget ($75,000-$150,000 total)
Select CMMC consultant or managed service provider
Begin documenting CUI data flows
Start creating System Security Plan (SSP)

Implementation Phase

Q1 2026 (January - March)

This Quarter's Investment: $30,000-$50,000

• Deploy EDR on all endpoints
• Implement SIEM for logging
• Create 20+ security policies
• Network segmentation project
• Vulnerability scanning deployment
• Complete staff security training

Hardening Phase

Q2 2026 (April - June)

This Quarter's Investment: $20,000-$40,000

• Internal assessment with consultant
• Address all critical findings
• Complete POA&M documentation
• Encrypt all CUI at rest/transit
• Test incident response plan
• Finalize all documentation

Certification Phase

Q3 2026 (July - September):

This Quarter's Investment: $15,000-$30,000

• C3PAO formal assessment
• Address any findings
• Submit final documentation
• Receive certification
• Update SAM.gov
• Celebrate!
  

The Prime Contractor Wild Card

If your prime requires certification before October 2026: Contact them TODAY to understand their timeline. Many are offering:

• Grace periods for suppliers showing progress
• Assistance programs and resources
• Shared cost arrangements
• Temporary workarounds

Don't assume you have until October 2026 – verify with each prime contractor NOW.

The Questions Every Manufacturer Asks

"Can we just wait until 2026 to start?"

Technically yes, but you'll regret it. Here's why: C3PAO assessment slots are filling up fast. Companies starting in January 2026 might not get assessed until November 2026 – missing the October deadline. Plus, some primes are requiring certification NOW. Boeing suppliers already know this pain.

"What if we fail the assessment?"

Most companies fail their first mock assessment – it's expected and why you start early. If you begin now, you can fail in March 2026, fix issues by June, and pass by August. Start in 2026? One shot, no room for error.

"Is this just expensive paperwork?"

No. Manufacturing is the #1 ransomware target. These controls would prevent 85% of attacks. One client told us: "We spent $120K on CMMC but saved $400K from prevented ransomware. The compliance was just a bonus."

"How do we handle legacy equipment?"

Document compensating controls. Can't patch that Windows XP CNC machine? Isolate it, monitor access, and document why. Starting now gives you time to properly document these exceptions. C3PAOs understand manufacturing realities when you show good faith efforts.

"What about our small suppliers?"

Notify them TODAY. They need the same 12-month runway you do. Many primes are creating supplier assistance programs. Get in those programs now before they fill up.

The Bottom Line

The CMMC program officially launches October 1, 2025. Full certification is required by October 2026. The math is simple: this allows 12 months to complete a 6-month process.

Here's what we think is going to happen over the next year.

• October 2025 - January 2026: 50,000 manufacturers realize they need certification
• February - May 2026: C3PAO assessment calendars book solid through December
• June - September 2026: Panic mode as companies realize they can't get assessed
• October 2026: Only companies that started in 2025 are certified

If you're a manufacturer handling defense contracts, starting in September 2025 puts you ahead  of your competition. You have time to:

• Do this right, not rushed
• Spread costs over fiscal years
• Properly train your team
• Build real security, not checkbox compliance
• Get your assessment slot before the rush

The manufacturers succeeding with CMMC aren't necessarily the largest or most sophisticated. They're the ones who started when they had 12 months, not 12 weeks.

Your Next 72 Hours

Day 1 (Today)

• Call your prime contractors - understand their requirements
• Contact 3 C3PAOs for quotes and timeline
• Calculate your current SPRS score

Day 2

• Schedule gap assessment for October
• Review your cyber insurance
• Identify your CMMC project lead

Day 3

• Draft your 2026 compliance budget
• Start documenting where CUI lives
• Book C3PAO assessment slot for Summer 2026
  

Need help navigating CMMC requirements? NOC Technology's CEO Jon Lober is a CMMC Registered Practitioner who has guided dozens of manufacturers through certification. We understand both the technical requirements and manufacturing realities. Contact us for a no-obligation consultation about your certification timeline.
Remember: The difference between companies that make the October 2026 deadline and those that don't isn't capability – it's when they started. Today is your day to start.